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State v. Martin

New Jersey Supreme Court
573 A.2d 1359 (1990)



Martin (defendant), who was heavily intoxicated, was evicted from a party in a third-floor apartment. A few minutes after Martin left, one of the guests noticed that the building was on fire. Everyone escaped except for one woman who had fallen asleep in the apartment and died of asphyxiation from the fire. Martin was accused of setting the fire and charged with arson, aggravated arson, and felony murder. At his trial, Martin testified that he lit a trash bag with a match but intended only to make a mess and did not think the fire would spread or hurt anyone. The State (plaintiff) offered expert testimony that the fire was started by pouring kerosene between the first and second floors of the building. The trial court instructed the jury that Martin was guilty of felony murder even if he started the fire recklessly, unintentionally, or accidentally. Martin was convicted on all three charges and appealed to the Appellate Division, which affirmed the convictions. Martin then appealed to the Supreme Court of New Jersey.

Rule of Law


Holding and Reasoning (Pollock, J.)

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