State of Tennessee, Appellee v. Steven B. Buggs, Appellant

Summary

The Tennessee Supreme Court affirmed Steven Buggs's felony-murder conviction for killing Karen Beasley, concluding the evidence supported a finding that he killed her in the perpetration of a robbery because he returned home to get money for cocaine, stabbed her when she stood in the way of that purpose, and immediately took their remaining cash. The court adopted the majority rule that intent to commit the underlying felony must exist prior to or concurrent with the act causing death, rejecting 'afterthought' felony murders, and overruled Mullendore v. State to the extent it presumed intent from the act of taking property, while preserving the rule that juries may infer prior or concurrent intent from a defendant's actions immediately after a killing. It further held that the absence of a supplemental instruction on afterthought takings was technically waived and, addressed on the merits, was not plain error because the pattern-based instruction fully informed the jury, and it rejected the claim that the circumstantial evidence of intent was insufficient. No separate opinions were filed.