State v. Robinson

Clyde Crowley, believing his sons were being threatened by a group of boys led by Jeremy Hendrickson, confronted the group, including fourteen-year-old Jerry Lee Robinson (defendant), at a park. A brawl broke out involving a knife, a baseball bat, and golf clubs; after Crowley struck one boy twice with the bat and was in turn struck by another with a golf club, Robinson struck Crowley in the head with a golf club, the club became lodged in Crowley's skull, and Crowley died. Robinson was convicted of depraved-heart second-degree murder after the jury was instructed on both that offense and the lesser-included offense of involuntary manslaughter, and he appealed, arguing the two offenses were functionally identical and thus arbitrarily distinguished.