State v. Hunter – Case Brief (IRAC Format)

⚖️ State v. Hunter (1987)
Court: Supreme Court of Kansas
Date: July 17, 1987
Opinion Filed:
❓ Issue

Whether the compulsion defense is available to a defendant charged with felony murder.
📜 Rule

Kan. Stat. Ann. Section 21-3209 provides for the defense of compulsion to crimes other than murder or manslaughter, stating:
(1) A person is not guilty of a crime other than murder or voluntary manslaughter by reason of conduct which he performs under the compulsion of threat of the imminent infliction of death or great bodily harm, if he reasonably believes that death or great bodily harm will be inflicted upon him or upon his spouse, parent, child, brother, or sister if he does not perform such conduct.
The limitation to the use of the compulsion defense is restricted to crimes of intentional killing and that, where compulsion is a defense to an underlying felony under Kan. Stat. Ann. Section 21-3209 so that the felony is justifiable, compulsion is equally a defense to charges of felony murder.
🔍 Analysis

The appellate court is reviewing whether the trial court erred by not giving the compulsion instruction to the jury. They believe that the defense the defendant raised should be accepted and reviewed within the court because the facts show that the acts Hunter had committed were done under compulsion.
When reviewing the facts, the court determines that Hunter did commit crimes and aided the perpetrator, but he acted under compulsion as there was a consistent threat to his life during the felonies. Hunter testified several key facts establishing his fear during the situation:
Remeta fired the .22 three times out of the car window.
When Hunter asked to be let out of the car, Remeta refused and began to talk about the hitchhiker he wished he had killed.
Remeta took out two bullets and asked Hunter if he thought they could kill him.
Remeta told Hunter he shot a girl five times with one of the weapons.
Remeta fired the .22 in the direction of Hunter when the car was stopped.
Remeta told Hunter he had killed a man for $40 and had killed 12 other people.
These constant threats by Remeta were enough for Hunter to justifiably fear for his life. The fear was thus reasonable and imminent as Remeta was constantly present with a weapon in his hands, posing an obvious danger to Hunter.
Additionally, the compulsion defense is only limited when there is an intentional killing. Because Hunter was forced to commit the felony under compulsion, the defense may still apply to him despite the initial crime being a lesser felony. This means that even though the crime developed from an assault to a murder as the situation continued, the defense still applies.
✅ Conclusion

The court reviewed Hunter’s trial court case while considering the compulsion defense that was raised and rejected by the trial court. When the defense of compulsion became evidently applicable to Hunter under the totality of the circumstances, the court decided that the trial court erred in not giving the jury the compulsion defense instructions. The case must have a new trial.
Examination:

Compulsion is a defense to felony murder if the underlying felony was compelled.
Imminence plus immediacy: A course of threats and constant menace can constitute duress in the eyes of the law.
 Rules of the jury must instruct on valid defenses if there is evidence in their support in the record.
Oftentimes the distinction between accomplice liability and duress is a question of fact, and it has to be determined judiciously.


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