State v. Martin
Supreme Court of New Jersey
573 A.2d 1359 (1990)
Martin (defendant), while heavily intoxicated, was evicted from a third-floor apartment party. Minutes later a fire broke out in the building, and a woman who had fallen asleep inside died of asphyxiation. The State (plaintiff) charged Martin with arson, aggravated arson, and felony murder, presenting expert testimony that the fire was started with kerosene. The trial judge instructed the jury that Martin was guilty of felony murder even if he started the fire recklessly, unintentionally, or accidentally. Martin was convicted on all counts, and the Appellate Division affirmed.
Whether a defendant may be convicted of felony murder when the death is too remotely related to the underlying felony, too accidental in nature, or too dependent on the voluntary acts of others for the defendant to be justly held responsible.