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The California Supreme Court upheld two murder convictions on Monday even though both young defendants claim the 58-year-old victim was still alive when they left the scene. The decision clarifies the state’s felony murder rule, which lets accomplices to inherently dangerous crimes be charged with murder even if they weren’t the actual killer. The court ruled unanimously that there must be a causal connection between the death and the underlying crime — robbery in this case — as well as proof that both were part of a single criminal act. “The causal relationship is established by proof of a logical nexus, beyond mere coincidence of time and place, between the homicidal act and the underlying felony the non-killer committed or attempted to commit,” Justice Marvin Baxter wrote. “The temporal relationship is established by proof the felony and the homicidal act were part of one continuous transaction.” James Cavitt and Robert Williams were convicted in separate San Mateo County trials for the murder of Brisbane resident Betty McKnight during a 1995 robbery and burglary concocted by McKnight’s stepdaughter, Mianta. All three were in their teens at the time of the killing. The two boys had argued that Betty McKnight was still breathing when they left her house and raised the possibility that Mianta, whom they had tied up to appear as a victim, had freed herself and proceeded to suffocate the stepmother she despised. Jurors rejected that theory and sentenced both Cavitt and Williams to 25-years-to-life in prison for first-degree felony murder. Mianta McKnight copped a plea deal and was sentenced to 15-years-to-life for second-degree murder. Monday’s ruling is guaranteed to satisfy neither the boys’ defense lawyers nor the state attorney general. The defendants had argued that a non-killer can be liable for felony murder only if the act resulting in death facilitated the commission of the underlying felony, while the state contended that there need be no causal relationship between the robbery and the murder. “After reviewing our case law,” Baxter wrote, “we find that neither formulation satisfactorily describes the complicity aspect of California’s felony-murder rule.” Justices Kathryn Mickle Werdegar and Ming Chin wrote separate opinions in which they concurred with the majority, but differed on small issues. Werdegar, in a ruling joined by Justice Joyce Kennard, said she felt the standard jury instruction on felony murder is inadequate. In future cases, she said, trial court judges should clearly explain that there has to be a causal and temporal relationship between the underlying crime and the murder. Justice Chin wrote to say that he felt that the jury instruction could be improved, and suggested, as Werdegar had, that judges make sure jurors understand the rules. Cavitt was represented by San Francisco solo practitioner Neil Rosenbaum, while Williams’ lawyer was Menlo Park solo Paul Carroll. The state’s case was argued by San Francisco-based Deputy AG Jeffrey Bryant. The ruling is People v. Cavitt, 04 C.D.O.S. 5417.

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