An Up-Close Look at Florida’s Felony Murder Law

Our South Florida criminal defense lawyers know that most people are confused if not outraged by the apparent miscarriage of justice in the case of Ryan Holle, the young Florida man convicted of murder and sentenced to life in prison for a crime for which prosecutor’s agree he was not present.
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In addition to the fact that his absence from the crime scene was and remains indisputable, there is also no evidence that Holle (or anyone else involved) even knew a murder would take place. He was only “involved” in the incident insofar as he lent his car to his friend, who drove a couple of men to a house to steal marijauana; something went wrong, and one of the men who was dropped off in Holle’s car killed an 18-year-old girl.

Nevertheless, according to Florida’s so-called felony murder rule, codified in State Statute 782.04, anyone who is involved in the perpetration of certain felonies (including armed robbery) at any level can be charged with first-degree murder if a death (a murder by the perpetrator or a death due to the intervention of a police officer) occurs in the commission of said felony. Thus, although Ryan Holle merely lent his car to a friend, because a murder was committed by someone who was driven to the crime scene by someone driving Holle’s car, Holle will spend the rest of his life behind bars.

Back in 2003, after a night of drinking, Ryan Holle (then just 20 years old) lent his car to his friend, William Allen, Jr., as he had numerous times before. This time, as Holle recalls, he thought that Allen was going to pick-up food. Allen, in a deposition, recalled that Holle’s only words regarding the car was “use the car,” and noted that nobody, including and especially Holle, ever knew that a murder would take place.

Allen, after taking the keys from Holle, proceeded to drop-off three men at the house of a known marijuana dealer; the plan was to remove a safe containing a pound of marijuana and roughly $1,400. During the burglary, however, things went wrong and one of the men who had been dropped-off at the house beat to death the 18-year-old daughter of the drug dealer with a shotgun he found in the house.

When the case went to trial, Holle was offered a plea bargain; if he accepted the deal, he would have received just ten years behind bars. However, knowing that he had nothing to do with the murder, Holle opted to refuse the deal and go to trial, expecting that a jury of his peers would realize that his lending his car to Allen was an act so far detached from the issue at hand, the murder, that he couldn’t possibly be found guilty of first-degree murder. Alas, Florida’s aforementioned felony murder law leaves almost no room for interpretation; once the prosecution had established that Holle was told that the car would be used in the commission of a (felony) robbery, and despite the fact that Holle, in a drunken stupor, thought that the supposed plan was actually a joke, the jury had virtually no option but to find him guilty given the applicability of s. 782.04.

The entire trial, from testimony to jury deliberations and then to conviction and sentencing, transpired in a single day.

When a man’s life is on the line, our criminal defense lawyers believe the court system should take the facts of the case a bit more seriously. Having an entire trial, the result of which condemned Ryan Holle to life imprisonment for a murder nobody argues he committed, last just one day is evidence of either indifference or injustice.

Florida’s felony murder law leads to the frequent life imprisonment of essentially innocent people. Engaging in felonies of any type is wrong, but to find as comparable the detached, non-active participation in a robbery with a first-degree murder exemplifies a costly false equivalency.

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