Langford v. State
Supreme Court of Alabama
354 So.2d 313 (1977)
Relevant factsFree
Langford (defendant), after drinking, sped and lost control of his car, fatally crashing into another vehicle; the State prosecuted him for first-degree murder based on universal malice rather than a lesser homicide charge, and the evidence showed only that he knowingly drove after drinking, not that he was determined to cause a collision or knew one was likely and proceeded anyway. His motion for a directed verdict was denied, and the jury convicted him of first-degree murder.
IssueFree
Whether universal malice refers to a person's depraved determination to take life upon slight or insufficient provocation, without knowing or caring who may be the victim.