Article: The felony murder rule in Illinois: the injustice of the proximate cause theory explored via research in cognitive psychology.

I. INTRODUCTION

In the summer of 2006, the Illinois Supreme Court affirmed two first-degree murder convictions in People v. Hudson (1) and People v. Klebanowski. (2) Both cases involved eerily similar fact patterns where an off-duty police officer, unbeknownst to the perpetrators, happened to be a target of an armed robbery. (3) In both cases, the officer fatally shot one of the felons, and the defendant was convicted of first-degree murder for the death of his accomplice. (4) The Illinois Supreme Court upheld both convictions under the felony murder rule and reaffirmed its allegiance to the proximate cause theory of felony murder. (5)

The proximate ...

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