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Langford v. State

Supreme Court of Alabama
354 So.2d 313 (1977)


Facts

Heflin Mack Langford (defendant), who had been drinking, drove his car, sped, lost control of the car, and fatally crashed into a car driven by Randall Holt. It was unclear whether Langford was legally drunk and decided to drive anyway, that he knew he was driving recklessly, or that he did so without regard to the lives he might be endangering. The State of Alabama (plaintiff) chose to prosecute Langford for first-degree murder resulting from universal malice, rather than for second-degree murder or some lesser charge. At the conclusion of the prosecution's evidence, Langford moved for a directed verdict, contending that even if the jury believed that Langford knew he was drunk but nevertheless intentionally drove the car that crashed into Holt's vehicle, this was insufficient to convict Langford of first-degree murder. The judge denied the motion and the jury convicted Langford of first-degree murder. Langford appealed to the Supreme Court of Alabama.

Rule of Law

Issue

Holding and Reasoning (Jones, J.)

Dissent (Maddox, J.)

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