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Northington v. State
Alabama Court of Criminal Appeals
413 So. 2d 1169 (1981)
Lana Northington (defendant) was charged on two counts in connection with the death of her five-month-old daughter. The first count charged that Northington recklessly engaged “in conduct which manifested extreme indifference to human life” and caused her daughter’s death by “withholding food and medical attention.” The second count charged Northington with intentionally suffocating her daughter. The jury convicted on the first count. Northington appealed, arguing that under Alabama law, extreme-indifference murder required outrageous conduct creating a grave risk of death to more than one person, not just one person in particular.
Rule of Law
Holding and Reasoning (Bowen, J.)
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