// Workers AI · dad joke modeWhat did Aaron say at trial? "I'm a-peeling the verdict.

People v. Aaron
Court	Michigan Supreme Court
Full case name	People of the State of Michigan v. Stephen J. Aaron
Decided	November 24, 1980 (1980-11-24)
Citation	299 N.W.2d 304; 409 Mich. 672
Case history
Appealed from	Michigan Court of Appeals
Court membership
Judges sitting	Kavanagh • Williams • Coleman • Levin • Fitzgerald • Ryan • Moody
Case opinions
Held: (1) Murder in Michigan is common-law murder; the elements of murder are established solely by case law. (2) Felony-murder requires malice equivalent to murder, is thus redundant, and is therefore abolished.
Decision by	Fitzgerald
Concurrence	Williams
Concur/dissent	Ryan

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. 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.

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).