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Appellate Court of Indiana - 13 Cox Crim. Cas. 550, 555, 557
Tags: Collateral felony
tl;dr:
Man accidentally starts fire on boat while attempting to steal rum. Conviction for arson quashed because jury improperly directed.Video Summary
Case Summary
In the 1877 case of Regina v. Faulkner, the Irish Court for Crown Cases Reserved overturned Robert Faulkner's conviction for arson after he accidentally set a cargo ship on fire while attempting to steal rum. The case demonstrated that the intention to commit one crime does not automatically extend to any unintended consequences.
Faulkner, a seaman, broke into the ship's storage and drilled a hole in a rum cask. When the rum spilled, he lit a match to see better and accidentally dropped it in the cask, causing a fire that destroyed the ship. While he was convicted of theft and arson, Faulkner appealed the arson charge.
The court ruled that Faulkner couldn't be guilty of arson unless he intentionally set the ship ablaze or was reckless concerning the fire's potential. The judges argued that there was no direct link between his intention to steal and the accidental fire, and that lighting a match wasn't inherently dangerous or unlawful. Additionally, the court rejected the idea that Faulkner's theft made him responsible for any ensuing harm, noting that this approach only applied to homicide cases under common law. The case is significant because it clarified the concept of transferred malice and restricted the range of felony murder.
DeepDiveHighlight a legal term to see the definition
The State of Indiana contracted for a year's supply of coal for a penal institution at a price of $3.40 per ton. A railway company delivered a carload of coal of the same kind and quality to the prison by mistake, which was consumed. The railway company sued the state to recover the market value of the coal, which was $6.85 per ton, but the court limited recovery to the contract price. The railway company is appealing the decision. The state's obligation to pay is quasi-contractual, and it must make restitution in value for the benefit received. The nature of the action is unusual and requires further consideration.
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