State v. Hokenson
Supreme Court of Idaho
527 P.2d 487 (1974)
Relevant factsFree
Fred Hokenson (defendant) entered a drug store armed with a homemade bomb to commit robbery; during the attempted robbery he attacked the store owner, and the bomb fell to the ground. Police arrested Hokenson, and as an officer picked the bomb up from the floor, it exploded and killed him. Hokenson was convicted of first-degree murder and appealed, arguing the killing could not support murder liability because it occurred after his arrest.
IssueFree
Whether an individual may be guilty of murder for a homicide that occurs as a consequence of his attempt to commit a felony, when the killing does not happen until after he has already been arrested and is in police custody.