State v. Allen

Jeffrey Edward Allen was convicted of first degree felony-murder in the Circuit Court for Charles County. The Court of Special Appeals reversed his conviction on the grounds that a defendant cannot be found to have committed felony-murder on the basis of a determination that he formed the intent to rob the victim only after he inflicted the fatal injuries. Allen v. State, 158 Md.App. 194, 857 A.2d 101 (2004). We granted the State’s petition for writ of certiorari to decide the following question:

“Can a defendant be found guilty of felony-murder, even if he did not form the intent to steal…