People v. Geiger

Late one evening, Mr. Geiger (defendant) confronted his estranged wife as she was about to enter a bar with Joan Greening. Greening testified that she observed Mr. Geiger force Mrs. Geiger into his car. Mr. Geiger then drove to a schoolyard, where he and Mrs. Geiger got out of the car and argued. Mr. Geiger struck his wife two or three times with his open hand and pushed her to the ground in such a manner that she bumped her head against the car, after which point she appeared unconscious. Mr. Geiger placed her in his car, drove to a trailer the pair had rented, and attempted to clean Mrs. Geiger. The following morning, Mr. Geiger left his wife in the trailer and persuaded a friend to help move the car that Mrs. Geiger had driven to the bar. When the friend asked what was going on, Mr. Geiger stated that he might be “facing a murder rap.” Mr. Geiger then awoke his boss and asked for some cash in order to get away for a few days. Mr. Geiger returned to the trailer, placed his wife in his car, and drove over 180 miles before stopping at a hospital where Mrs. Geiger was pronounced dead. The coroner testified that Mrs. Geiger had been struck by a blunt object such as a hand or a fist and died as a result of choking while attempting to vomit. Mr. Geiger related the incident to the police but neglected to mention that he had forced Mrs. Geiger into his car and his visits to his friend and to his boss. Mr. Geiger was charged with first-degree murder, but the jury was instructed only as to second-degree murder and manslaughter. Mr. Geiger was convicted of manslaughter and appealed, arguing that the trial court had erred in instructing the jury on second-degree murder in the absence of proof of malice.