People v. Stamp, 2 Cal. App. 3d 203, 82 Cal. Rptr. 598 (Cal. Ct. App. 1969)
People v. Stamp is a leading California case on the scope of the felony-murder rule and criminal causation.
Does the felony-murder rule impose first-degree murder liability when, during the commission of a robbery, the victim dies from a heart attack precipitated by fright and stress, notwithstanding the victim's preexisting heart condition and the unforeseeability of death?
Under California Penal Code § 189, a killing committed in the perpetration of an enumerated felony, including robbery, is murder of the first degree. The felony-murder rule imputes malice as a matter of law and does not require proof that the death was intended, foreseen, or a natural and probable consequence. So long as the homicide is the direct causal result of the felony—i.e., the felony is a substantial factor contributing to the death—the felon is strictly liable for murder and takes the victim as he finds him.
Yes. The court affirmed the first-degree murder convictions, holding that the felony-murder rule applies because the robbery directly precipitated the victim's fatal heart attack, regardless of foreseeability or the victim's preexisting physical frailty.
People v. Stamp is a cornerstone case in criminal law teaching for two reasons. First, it exemplifies the breadth of the felony-murder rule in California as it existed at the time: strict liability for deaths proximately caused by enumerated felonies, with no foreseeability requirement and no need to prove malice or intent to kill. Second, it clarifies the causation floor for felony-murder—requiring a direct causal connection and embracing the eggshell victim principle in criminal homicide. The case is frequently used in exam problems to test students' understanding of felony-murder, causation, and the res gestae/escape phase of a felony. (Students should also be aware that California has since reformed aspects of felony-murder liability by statute, but Stamp remains historically and doctrinally important.)