--- title: "People v. Stamp" type: Landmark Case source: https://casebriefly.com/landmark-cases/people-v-stamp --- # People v. Stamp This case is the leading authority on the felony murder rule's broad application of causation, holding that the felony murder rule imposes strict liability for any death that is a direct causal result of the felony, regardless of how foreseeable the particular manner of death was. The victim's pre-existing condition (obesity and heart disease) did not break the causal chain. The case illustrates the eggshell victim principle in the criminal law context. ## Citation 2 Cal. App. 3d 203 (Cal. Ct. App. 1969) ## Year 1969 ## Court California Court of Appeal ## Facts Stamp and an accomplice robbed a business at gunpoint. During the robbery, the victim, Carl Honeyman, was forced to lie on the floor at gunpoint. Honeyman, who was obese and had a pre-existing heart condition, died of a heart attack approximately twenty minutes after the robbers left. Medical testimony established that the fright and stress from the robbery caused the fatal heart attack, though Honeyman might have died from his heart condition at some point regardless. ## Procedural History Stamp was convicted of first-degree felony murder. He appealed, arguing that the death was not foreseeable because it resulted from the victim's pre-existing condition rather than any violence by the defendant. ## Issue Whether the felony murder rule applies when the victim's death results from a heart attack caused by the fright and stress of an armed robbery, where the victim had a pre-existing heart condition that made him particularly susceptible. ## Holding The court affirmed the conviction, holding that the felony murder rule does not require that the death be foreseeable. A felon is strictly liable for all killings committed during and in furtherance of the felony, so long as the death is the direct causal result of the felony. The victim's pre-existing condition does not break the chain of causation. ## Reasoning The court reasoned that the felony murder rule is designed to deter felons from killing by holding them strictly responsible for any death resulting from their felonious conduct. The doctrine does not require the prosecution to prove that the death was a natural or probable consequence of the felony, only that it was a direct causal result. The court applied the eggshell victim principle, holding that a felon takes his victims as he finds them and cannot escape liability because the victim was particularly vulnerable due to age, health, or physical condition. The stress and fright of an armed robbery directly caused the heart attack, satisfying the causation requirement regardless of the victim's pre-existing susceptibility. ## Impact People v. Stamp is the standard casebook case for teaching the felony murder rule's approach to causation. It illustrates the rule's harshness and its departure from normal causation principles by imposing liability without regard to foreseeability. The case is frequently cited in debates over the felony murder rule's fairness and has been used to argue for reform or abolition of the rule in many jurisdictions. ## Key Quotes - A felon is held strictly liable for all killings committed by him or his accomplices in the course of the felony. - So long as the homicide is the direct causal result of the robbery, the felony-murder rule applies whether or not the death was a natural or probable consequence of the robbery. - The defendant takes his victim as he finds him. ## Related Cases - people-v-acosta - velazquez-v-state - people-v-patterson - pinkerton-v-united-states ## Exam Relevance People v. Stamp is frequently tested in questions about the felony murder rule and causation. Exam hypotheticals may involve a victim with a pre-existing condition who dies during or after a felony, and students must analyze whether the death satisfies the causation requirement under the felony murder rule. The case is also used in policy questions about the justifications for and criticisms of the felony murder rule. ## Study Tips - Remember that the felony murder rule applies a strict liability standard to causation: any death that is a direct causal result of the felony suffices, without regard to foreseeability. - Understand the eggshell victim principle as applied in criminal law: the defendant takes the victim as he finds him. - Contrast the felony murder rule's causation standard with the normal proximate cause analysis in non-felony murder cases. - Be prepared to discuss policy arguments for and against the felony murder rule, including deterrence, proportionality, and individual culpability. ## Doctrine Established Felony Murder Rule's Strict Liability Causation Standard --- Source: [People v. Stamp — CaseBriefly](https://casebriefly.com/landmark-cases/people-v-stamp)