James Cavitt v. Vince Cullen

James Freddie Cavitt and his girlfriend Mianta McKnight robbed the house of Betty McKnight, Mianta’s stepmother. Cavitt admits that he and Mianta robbed the victim’s home and left her hogtied and face-down with a sheet taped around her head. He contends, however, that Betty was alive, albeit breathing laboriously, when he left. Betty McKnight was not breathing and had no pulse by the time police arrived 22 minutes later. Cavitt speculates that, after he left, Mianta killed Betty because of personal hatred, a motive he says was unrelated to the robbery. The state trial court, reasoning that Cav-itt’s theory, even if true, would not absolve him of felony murder, did not let him present his theory to the jury. He was convicted of felony murder.

The California Supreme Court held that, regardless of who killed Betty, Cavitt could be liable for felony murder because there was a “logical nexus” between the robbery and Betty’s death. Seeking a federal writ of habeas corpus, Cavitt argues that the California Supreme Court’s decision violated his constitutional rights. Specifically, he argues that the “logical nexus” requirement is unconstitutionally vague, that its application in…