United States v. García-Ortiz

Jose A. Garcia-Ortiz (Garcia) (defendant), identified through eyewitness testimony, DNA, and other forensic evidence, participated with Reinaldo Rolon Rivera (Rolon) in an armed robbery of a grocery-store manager and security guard on their way to deposit the store's receipts; the guard traded gunfire with the robbers, wounding him, while Rolon was killed and Garcia was wounded. Garcia was prosecuted for first-degree murder under the federal felony-murder rule, and the trial judge instructed the jury it only needed to find that Garcia committed the underlying felony (robbery affecting interstate commerce) and that a person -- here, Garcia's own accomplice Rolon -- was killed as a result. Garcia was convicted and appealed, arguing this instruction and the underlying felony-murder theory were improper.