STATE OF RIDGEWAY
STATE SUPERIOR COURT
STATE OF RIDGEWAY
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BRIEF IN SUPPORT OF STATE’S
TRIAL ARGUMENTS
Plaintiff
v.
Iamthebestlaith
Defendant
BRIEF IN SUPPORT
FIRST-DEGREE MURDER STATUTE
The Ridgeway First-Degree Murder statute provides that a person is guilty of First-Degree Murder if
they do one of the following: (1) kill another in the course of of committing or attempting to commit
kidnapping, burglary, robbery, arson, obstruction or retaliation (2) kill a peace officer or civil department
employee discharging a lawful and official duty, with the knowledge of the person being a peace officer or civil
department employee (3) kill another with malice aforethought. The defense asserts in this case that since the
First-Degree Murder statute has the words “committing murder” instead of the words “cause the death of” or
“kill”, the statute should be interpreted as one of the required elements for a defendant to be guilty of
First-Degree Murder being malice aforethought. This proposed interpretation goes against the clear intent of the
legislature, which is explained below.
LEGISLATIVE INTENT
When interpreting the law, the primary goal of the judiciary is to interpret the intent of the legislature,
and the court has many tools to do this such as reading the text of the statute, and looking at similar laws.
Numerous real life U.S States make the act of killing a peace officer First-Degree Murder rather than
Second-Degree Murder, despite there being no premeditation or malice aforethought. This is due to the fact that
killing a peace officer is seen as a more serious offense in the legislature’s view. A simple search of real life
first-degree murder statutes will easily cause a person to find statutes which make it first-degree murder to
intentionally kill a peace officer who’s on-duty. Based on the fact that numerous real life U.S States make it
First-Degree Murder to kill a peace officer without malice aforethought or premeditation, the only reasonable
conclusion based off the ambiguity of the definition of the word “murder” is that the ridgeway legislature
intended for the word to simply mean to kill, and not killing another with malice aforethought.
Furthermore, the interpretation of the legislature’s definition of “murder” by the defense doesn’t make
sense. If the legislature’s intent was to make the word “murder” mean killing with malice aforethought, then
that means that the legislature included a bunch of unnecessary language in the statute. Let’s say that the
legislature did intend to define the word “murder” as killing with malice aforethought. First, why did the
legislature feel the need to explicitly define it as that right at the end as the third way of committing
First-Degree Murder, since the statute defines the third way of committing First-Degree Murder as, “or of
committing murder with malice aforethought.” Second of all, if the interpretation of the statute from the defense
is correct, then why did the legislature feel the need to provide three ways of committing First-Degree Murder?
If the word murder was really meant to be interpreted as killing another with malice aforethought, then
why did the legislature find the need to include in the statute that First-Degree Murder is defined as, “The act of
committing murder in the course of committing or attempting to commit kidnapping, burglary, robbery, arson,
obstruction or retaliation; or of committing murder of a peace officer or civil department employee discharging
a lawful and official duty, with the knowledge of the person being a peace officer or civil department
employee”. If the interpretation from the defense is correct, then the legislature would’ve just defined
First-Degree Murder as “committing murder against another person” or “killing another with malice
aforethought”, and this text would already define the first two ways a person could commit First-Degree Murder
easily; but the legislature didn’t, and that’s because the intent of the legislature was not at all to define murder as
killing another with malice aforethought.
DEFINITION OF MURDER BY THE LEGISLATURE
The intent of the legislature when authoring the First-Degree Murder statute is made clear by the
wording of the law and other laws which are basically the exact same passed in other jurisdictions, and that is to
define the word “murder” as simply killing another person. This is an interpretation which would make
complete sense under the context and wording of the statute. The interpretation from the defense is absurd when
the text of the statute and context are taken into account. Why did the legislature feel the need to write three
ways a person could commit First-Degree Murder if the third way encompasses the first two? Did the
legislature really intend the statute to only criminalize killing peace officers with malice aforethought, while
numerous U.S States have a statute named something along the lines of First-Degree Murder or Capital Murder
which criminalizes killing peace officers without malice aforethought? The answer to both of these questions is
obviously no, as the interpretation from the defense is absurd and makes no sense.
Interpreting the word “murder” in the statute as killing another person is the interpretation which makes
sense, would fit perfectly, and aligns with the intent of the legislature. Contrary to that, interpreting the word
“murder” in the statute as killing another person with malice aforethought makes no sense, and goes directly
against the clear intent of the legislature. Therefore, this court ought not to interpret the First-Degree Murder
statute as requiring the prosecution to prove malice aforethought in order to secure a conviction, when the
prosecution has already proven that the defendant killed a peace officer discharging a lawful and official duty,
with the knowledge the person was a peace officer.
Also, no court has ever interpreted the First-Degree Murder statute in the manner the defense is asking
this court to do. In all State Superior Court cases, the court has interpreted that a person is guilty of First-Degree
Murder when it’s proven beyond a reasonable doubt that the defendant killed a peace officer, who was
discharging a lawful and official duty, with the knowledge that the person was a peace officer. State of
Ridgeway v. Quietous RSC-CM-356 At no time has a court ever added an additional requirement of proving
malice aforethought when all of these elements are proven, as the statute doesn’t require malice aforethought
when it’s proven that the defendant killed a peace officer discharging a lawful and official duty with the
knowledge the person was a peace officer. This court should hold the same as all of the other cases, and not
require the prosecution to prove malice aforethought in this case when it’s already been proven that the
defendant killed a peace officer, who was discharging a lawful and official duty, with the knowledge that the
person killed was a peace officer.
Respectfully Submitted,
/s/ andysofun
andysofun, RSB#17143
