People v. Stamp

California Court of Appeal · 1969 · Criminal Law

2 Cal. App. 3d 203 (1969)

Updated August 1, 2026

Criminal Lawfelony murdercausationrobberyheart attackdirect causal resultforeseeabilityeggshell victim

Facts

Koory and Stamp, armed with a gun and a blackjack, robbed the General Amusement Company while Lehman drove the getaway car. During the robbery, owner Carl Honeyman appeared frightened and pale, and after the robbers left he was short of breath, rubbing his chest, and complaining that his heart was pounding too fast. About 15 to 20 minutes after the robbery, Honeyman collapsed and was pronounced dead; the coroner listed the immediate cause of death as heart attack. Three prosecution medical experts testified that although Honeyman had advanced heart disease, some immediate upset precipitated the fatal attack and that but for the robbery he would not have suffered the fatal seizure at that time.

Issue

Whether the felony-murder rule applies when robbery fright causes a victim with preexisting heart disease to suffer a fatal heart attack, even though the death was allegedly unforeseeable. Also, whether the evidence was sufficient to show that the robbery legally caused the victim's death.

Rule

Under Penal Code section 189, a killing committed in the perpetration of robbery is first degree murder whether intentional, accidental, or unintentional, so long as the homicide is the direct causal result of the robbery and occurs as part of one continuous transaction. The doctrine is not limited to foreseeable deaths, and a robber remains responsible when the victim's predisposing physical condition is not the only substantial factor in causing death; the robber takes the victim as he finds him.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

In Fresno, Victor Lane and Omar Ruiz robbed a small payroll office at gunpoint. The manager, Ellen Park, had severe undiagnosed coronary disease, appeared terrified during the robbery, complained that her chest was pounding immediately afterward, and collapsed 12 minutes later; medical testimony stated that the fright precipitated the fatal attack when it occurred.

Are Victor and Omar most likely guilty of first-degree felony murder for Ellen's death?

Explanation. Under the majority rule, robbery felony murder applies when the homicide is the direct causal result of the robbery and occurs as part of one continuous transaction. Foreseeability is not required, and the robber takes the victim as found. A predisposing physical condition does not defeat liability unless it is the only substantial factor causing death.