King v. Commonwealth
Court of Appeals of Virginia
368 S.E.2d 704 (1988)
Nelson James King (defendant) and Mark Lee Bailey were flying a small plane carrying over 500 pounds of marijuana for a drug-smuggling operation when they became lost in heavy cloud cover; while King examined navigation maps, Bailey piloted the aircraft, which crashed into a mountain, injuring King and killing Bailey. King was charged with felony homicide based on Bailey's death combined with the underlying marijuana-distribution felony, convicted of second-degree murder, and appealed, arguing no direct link existed between the drug possession and Bailey's accidental death.
Whether, for the felony-murder rule to apply, the death of a victim must be directly related in time, place, and causal connection to the commission of a felony.