John Andrew Doubleday, Petitioner v. the People of the State of Colorado, Respondent

Summary

The court held that a felony-murder conviction requires proof beyond a reasonable doubt that the defendant committed the predicate offense, including proof that any properly asserted affirmative defense does not apply. Because the jury acquitted Doubleday of attempted aggravated robbery after finding that the prosecution failed to disprove duress, the predicate offense was not established and the felony-murder conviction could not stand. The court reversed and remanded for vacatur of the felony-murder conviction and sentence and reinstatement of the second-degree-murder charge.