People v. Aaron

People v. Aaron, 299 N.W.2d 304 (1980), was a case decided by the Michigan Supreme Court that abandoned the felony-murder rule in that state.^[1] The court reasoned that the rule should only be used in grading a murder as either first or second degree, and that the automatic assignment of the mens rea of the felony as sufficient for the mens rea of first degree murder was indefensible.^[2]

Michigan is unique among states that have abolished the felony-murder rule entirely in doing so by judicial decision. This was acceptable because, unlike most other states, the felony-murder rule, and indeed the definition of murder itself, was entirely a common law offense, i.e. inherited from English judge-made common law. Michigan's criminal code did have statute on murder, but as the court noted, it merely defined the criteria under which a murder would be considered a first-degree murder and therefore opened the defendant to harsher punishment (specifically mandating life imprisonment as the penalty, Michigan having abolished the death penalty for ordinary crimes in 1846).^[3]