On November 25, 1985, Sandy Patterson (defendant) and two women ingested cocaine that Patterson had furnished to the group. One of the women, Jennie Licerio, died of acute cocaine intoxication. Patterson was charged with Licerio's murder, among other crimes. Patterson moved to dismiss the murder charge, arguing that the evidence did not establish probable cause to believe that he had murdered Licerio. The prosecution (plaintiff) argued that Patterson was guilty of second-degree felony murder because he committed an inherently dangerous felony by furnishing cocaine to Licerio. The trial court dismissed the murder charge, and the prosecution appealed. The court of appeals affirmed the dismissal. The prosecution petitioned the state supreme court for review.