The State v. Jackson

Summary

The court held that the felony-murder statute's requirement that a defendant "cause" a death incorporates ordinary proximate-cause principles, rather than requiring the defendant or a co-felon to directly inflict the fatal injury. It overruled the prior contrary rule, reversed dismissal of the felony-murder counts, and remanded for a jury to decide causation under proper instructions. The dissents would have retained the prior interpretation based on the party-to-a-crime statute, statutory lenity, and legislative acquiescence.