Florida’s Felony Murder Rule

Man Loses Clemency Bid For Murder He Did Not Commit

Ryan Holle is serving a life sentence for the felony murder of Jessica Snyder. His petition for clemency went nowhere today, even though state investigators gave him a favorable recommendation.

His crime? Loaning his car to his friends so that they could burglarize a house to get drugs and cash. During the burglary one of his friends beat Jessica Snyder to death with a shotgun. While all this happened Holle was at his own home. State investigators found he had no knowledge or participation in the murder.

How did this happen? How could Holle be convicted of murder and sentenced to life in prison when he apparently had no idea his friends would kill someone while burglarizing the house?

Felony Murder

Holle was convicted of the murder under Florida’s “Felony Murder” law. This law says that

“When a human being is killed during the perpetration of, or during the attempt to perpetrate, any [burglary], by a person other than the person engaged in the perpetration of or in the attempt to perpetrate such felony, the person perpetrating or attempting to perpetrate such felony commits murder in the second degree.”

Basically, the felony murder law means that if a person participates in a felony, and one of his co-conspirators kills someone while carrying out that felony, he can be convicted of second-degree murder. Here’s an example: the get-away driver ion a bank robbery can be convicted of felony murder if one of the robbers shoots up the bank, even if the driver never gets out of the car.

The idea behind the felony murder rule is a desire to hold the people responsible for planning and carrying out a violent crime responsible for all the results of that crime, including someone’s death during the crime. So the person who plans the crime can be responsible for a murder committed during the crime, even if it wasn’t part of the plan.

Of course this broad rule means we have cases like Ryan Holle’s — he was convicted of felony murder even without intending or participating in the death of a burglary victim. The way the law is written, Holle could be convicted of felony murder if his friends drunkenly crashed his car and died on the way to the intended burglary.