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Hulme v. State

Under the circumstances, defendant's distribution of a lethal dosage of methadone to the victim supported defendant's felony murder conviction.

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Connie Hulme was convicted of felony murder, with the underlying felony of distribution of methadone, in connection with the death of Lisa Chastain Brown, who died of multiple drug intoxication.1 Because the record supports the conclusion that Hulme’s felony of distributing methadone was, under the particular facts of this case, a dangerous felony, and because the record supports the finding that Hulme directly caused Brown’s death in the commission of that felony, we conclude that the evidence is sufficient to support Hulme’s conviction of felony murder. Finding no merit to Hulme’s other contention, we affirm.

Brown was a drug addict who had been in and out of treatment programs. Brown’s sister, Deborah Headen, often drove Brown to and from various treating facilities. Approximately one month before Brown died, Headen asked Brown if she needed to pick up any prescription drugs. Brown replied that “she didn’t need to stop and get any, that Connie Hulme gave her ten milligrams of methadone a day.”

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