People v. Jones is a case that supports the argument that criminally negligent homicide is a different crime than first degree murder.
What are the facts of People v. Jones?
The defendant was charged with first degree murder. He argued that he should have been convicted of criminally negligent homicide. According to several witnesses, the defendant went to pick up his girlfriend from a friend’s apartment. He knocked on the door but received no answer. While he was knocking on the door, a neighbor came outside and he struck up a conversation with her and they went out for a drink.
When they came back from the bar, they went into the neighbor’s apartment. Shortly afterwards, the neighbor’s roommates said they heard the her screaming. One of the roommates ran into the living room and saw the defendant kneeling over the neighbor’s body, with his hand over her mouth, pulling a knife out of her chest. When the defendant saw the roommate standing in the living room, he ran out of the apartment.
When the police caught the defendant, he told them that he hadn’t meant to hurt the victim. At trial, the defendant testified that he had not entered the apartment with the victim. Rather, he said he heard screaming and went inside to see what was happening. When he went inside, he found the victim on the floor with a knife in her chest. He ran away because he was sick at the sight of all the blood. The defendant’s testimony would have supported a conviction for criminally negligent homicide, but he was convicted of first-degree murder.
Is negligent homicide the same as first degree murder?
The defendant appealed his conviction to the Colorado Supreme Court. He argued that he should only have been convicted of criminally negligent homicide. His main argument was that the culpable mental state for first-degree murder was the same as criminally negligent homicide. The Colorado Supreme Court disagreed and ruled against him. The Colorado Supreme Court ruled that first-degree murder requires that the defendant act “. . . under circumstances manifesting extreme indifference to the value of human life. The Court suggested that the mental state of “extreme indifference” is clearly more culpable than the mental state of someone failing “to perceive a substantial and unjustifiable risk that a certain result will occur.” Therefore, the standards of culpability in the two laws are distinct enough to be intelligently understood and applied so it upheld his conviction for first degree murder.
