[ A draconian legal doctrine called felony murder has put
thousands of Americans—disproportionately young and Black—in
prison.]
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SENTENCED TO LIFE FOR AN ACCIDENT MILES AWAY  
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Sarah Stillman
December 11, 2023
The New Yorker
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_ A draconian legal doctrine called felony murder has put thousands
of Americans—disproportionately young and Black—in prison. _

Sadik Baxter is serving a life sentence without parole for a killing
he didn’t commit., Illustration by Hokyoung Kim

 

In 1982, when Ian Marcus was nine days old, his father left work and
headed home to his family on Long Island on a new moped, only to be
killed by a driver who’d run a red light. “Here I was, this
twenty-five-year-old widow with a baby,” Ian’s mother, Donna, told
me. About a year and a half after the accident, when a bearded guy who
ran a Brooklyn meat locker asked her out, “it took ten friends to
convince me to go.” Her date, Dean Amelkin, arrived with a plastic
train set for Ian. Before long, her son had a second dad, a second
last name, and two younger sisters.

The family relocated to South Florida, where Dean helped his own
father run a graphics shop. Eager for Ian and his sisters to achieve
more economic stability than he’d known, Dean pushed them
academically, weeping with pride when Ian won a national debating
championship in high school. Eventually, Ian went on to law school,
landing a job at an élite Manhattan law firm; as a kid, he had
watched “My Cousin Vinny” with his dad, and they’d agreed that
lawyering looked fun.

One Sunday morning in August, 2012, Ian, now thirty, was in bed in
Brooklyn when his mother called, distraught. Every Sunday for more
than a decade, Dean had met some buddies at a shopping center, biked
thirty miles to a beach and back, and then lingered over breakfast.
But on that morning Dean hadn’t made it home. For the second time in
his life, Ian had lost his father to a reckless driver.

This shock was swiftly followed by another. As a result of the crash,
which all parties agreed was unintentional, two men stood accused of
murdering his father and a friend who was cycling with him. One of
those charged, twenty-five-year-old Sadik Baxter, had never laid eyes
on the victims. At the moment of impact, he had been miles away, in
handcuffs.

When Donna heard the charges, she asked, How is this even possible?
Ian had learned the answer in law school: a sweeping and uniquely
American legal doctrine, often couched in terms of justice for
victims’ families, called felony murder. To engage in certain
unlawful activities, the theory goes, is to assume full responsibility
if a death occurs—regardless of intent.

The precipitating offenses in this case: Sadik Baxter had searched
five cars for stray cash before surrendering when cops appeared, and
O’Brian Oakley, his twenty-six-year-old friend, had fled the scene,
lost control of his car in a police chase, and killed the bicyclists.
The prosecution charged both men with two counts of felony murder in
the first degree.

Recently, Ian spoke with me about the case while caring for his
newborn daughter in Brooklyn; as we talked, he sometimes ran his hand
down a thick beard he’d grown in homage to his dad. “It’s truly
one of the cruellest ideas in the American legal system,” he said of
felony murder. “And most people don’t even know it exists.”

When Sadik Baxter was nine years old, he felt he’d discovered God
after tasting the fruits of his parents’ birthplace, Jamaica. He
devoured the soursop, the star fruit, and the jackfruit; his father, a
former cop in Kingston, took note. Sadik’s mother, who’d been
raising him just outside Miami, soon asked her ex to keep their son on
the island for a spell and instill in him some discipline and focus.
One way to do that, the father decided, would be to teach him to
nurture plants and fruit trees of his own—a project to which Sadik
became devoted.

A month before Sadik was arrested for killing the men he’d never
seen, his father phoned him to relay a disturbing dream. “Something
very bad is going to happen,” he warned, but this catastrophe might
be prevented if Sadik returned to his love of horticulture. At the
time, Sadik felt that something very bad had already happened—a
string of bad things, in fact. In a 2009 Miami night-club shooting,
he’d taken a stray bullet in his tailbone, and the long recovery had
cost him his job at the reception desk of a hotel. “Can you believe
I’m changing your Pampers again?” his mom teased as she took care
of him. Just as his gunshot injury began to heal, she had a stroke,
then died at the age of fifty-nine. In his grief and physical
distress, Sadik became addicted to painkillers.

His father, on the phone, put forward another way to live: Couldn’t
he import Jamaican plants and sell them in Florida grocery stores for
a hefty markup? Think Scotch-bonnet peppers! And doesn’t everyone
love a poinsettia at Christmas? His son could do something he liked
and make a living.

“Good idea,” Sadik replied, before returning to doing precious
little. One Saturday night soon afterward, he and O’Brian Oakley
played blackjack and downed free drinks at a suburban Miami casino.
Long after midnight, having lost a lot of money and popped a Percocet,
Sadik left the casino with O’Brian and ended up in Cooper City, a
nearby community of back-yard pools and luxe landscaping. It occurred
to Sadik, cruising the winding streets, that he could steal from cars
to offset his losses. O’Brian, a singer-songwriter, told me that he
resisted the proposal at first. But just before dawn he found himself
sitting in his parked silver sedan on a corner, as Sadik got out and
looked around.

Sadik was hardly inconspicuous; at six feet nine, he was so lanky that
his mom had called him Coconut Tree. Still, he had the benefit of the
dark. Like a kid up too early on Christmas morning, he discovered a
drum set in one unlocked car and an embroidered bag of baseball
equipment in another. Then he turned his attention to a black S.U.V.
sitting outside a home edged with palm trees. Inside the car, he
grabbed a handful of change and a pair of sunglasses, only to look up
and see a man striding toward him across the grass.

Bradley Kantor, a health-care entrepreneur, and his wife had just
returned from taking their son to the airport when they spotted a
stranger in their driveway. Sadik tried to saunter calmly away, but
Kantor ran back to his car and began driving slowly behind him, his
wife filming on her phone as he called 911. The first of several
Broward County Sheriff’s Office vehicles pulled up in two minutes.

“Get on the ground!” a deputy ordered. Sadik was handcuffed on the
grass while having a panic attack—not least because he was supposed
to pick up his four-year-old daughter, Danasia, that morning.

Moments later, O’Brian drove past. He had fled the scene when Kantor
arrived, but had gotten lost exiting the neighborhood and accidentally
circled back around. “That’s the car!” Kantor cried out.
O’Brian hit the accelerator, and multiple officers gave chase. They
trailed him at high speed through a residential neighborhood. Eighteen
minutes later, O’Brian ran a light and was struck by another
vehicle; his car crashed into Dean Amelkin and his friend Christopher
McConnell.

Sadik learned of the accident shortly before he arrived at the
sheriff’s office, where he confessed to stealing from five unlocked
cars. Wearing a blue hospital gown, his voice thick from medications
he’d been administered after his panic attack, he asked a detective
what would happen next. He’d be charged with burglary, the detective
replied. Three weeks later, Sadik received a written copy of his
indictment at a Broward County jail.

According to a grand jury, both he and O’Brian did “unlawfully and
feloniously kill and murder” two people. The prosecution had decided
not to pursue the death penalty, but the first-degree-murder charges
were punishable by life in prison without parole. Later, Sadik told
me, “That’s when I went crazy.”

What makes a murderer? Intent is often assumed to be a factor. But,
for hundreds of years, the felony-murder doctrine has muddled this
conceit.

In 1716, the legal theorist William Hawkins argued that a crime like
robbery “necessarily tends to raise Tumults and Quarrels . . .
and cannot but be attended with the Danger of personal Hurt.” Any
resulting death, he posited, was tantamount to murder. Such notions
began being applied in British courts later in the eighteenth century,
and, almost from the beginning, Britons were questioning whether the
felony-murder doctrine was just.

The question came to a head in 1953, when, despite widespread pleas
for clemency, a nineteen-year-old Londoner named Derek Bentley was
executed because his sixteen-year-old accomplice in a burglary killed
a policeman during the crime. Four years later, the U.K. abolished the
doctrine, and other Commonwealth nations followed suit. The United
States, meanwhile, went in the opposite direction.

According to Guyora Binder, of the University at Buffalo School of
Law, the modern felony-murder doctrine is best understood as “a
distinctly American innovation.” Although it was first applied early
in the nineteenth century, use of the charge surged in the
nineteen-seventies, when the era of mass incarceration began. Fifty
years later, Binder contends, no country relies on the doctrine more.

[Baxters daughter Danasia was four years old when he was arrested.]

Baxter’s daughter, Danasia, was four years old when he was
arrested.Photograph courtesy Tracy Grant

In Tulsa, two men attempted to steal some copper wire from a radio
tower and accidentally electrocuted themselves. One of them died and
the other was charged with first-degree murder while recovering from
his burns in the hospital; the girlfriend of the deceased was also
charged with murder, for having driven them to the tower. In Topeka, a
twenty-two-year-old made the mistake of hiding his gun atop his
girlfriend’s refrigerator; he was charged with first-degree murder
several days later, when a child inadvertently fired it at a
thirteen-year-old girl. In Minneapolis, a sixteen-year-old girl who
sat in the car while two older men killed someone in a robbery was
charged with felony murder. Deemed too young to enter the adult prison
population after her conviction, she was placed in solitary
confinement for months, purportedly for her own safety. In Somerville,
Tennessee, last May, three teen-age girls overdosed on fentanyl in
their high school’s parking lot before a graduation ceremony. Two of
them died, and the surviving girl was charged with murder.

For prosecutors, the felony-murder rule offers an efficient path to
conviction: winning a case is much easier if you don’t need to prove
a person’s mens rea—“guilty mind”—or even, in some cases, to
establish that the accused was at the scene of the crime. Forty-eight
states now have some version of the statute. Charlie Smith, the
president of the National District Attorneys Association, told me that
the tool is particularly useful in cases with vulnerable victims, such
as an elderly woman in a wheelchair who gets assaulted in a
purse-snatching incident and dies. “The community would feel it’s
not reasonable if the old lady’s death was just a simple misdemeanor
assault,” he said. Prosecutors often employ felony murder when a
death results from an armed robbery—a category of crime that Smith
contends, in the spirit of Hawkins, carries death as a foreseeable
outcome.

Another benefit to prosecutors is that the steep penalties often
attached to felony murder—including life sentences—compel
defendants to plead guilty to a lesser charge. “We shouldn’t
underestimate how many plea bargains occur in the shadow of
felony-murder charges across the country,” Ekow Yankah, a law
professor at the University of Michigan, told me. “It is one of
those quiet drivers of mass incarceration we never acknowledge.”

Remarkably, no one knows how many people in the United States have
been imprisoned for the crime. So in 2022, working with students and
colleagues at the Yale Investigative Reporting Lab, I decided to try
to get a sense of the scale. We started by filing public-records
requests to state corrections departments and other agencies across
the country; to our surprise, most told us that they weren’t keeping
track. “The records do not exist,” an official at the Virginia
Department of Corrections wrote, in a typical response. In most
states, a felony-murder conviction gets lumped in with other types of
murder, clouding the data. It was as if the extent of felony murder in
America were hidden by design.

When we eventually secured robust data from eleven states, our lab’s
analysts discovered that racial disparities for felony-murder
convictions were higher—sometimes far higher—than the already
disproportionate rates of Black incarceration over all. In Wisconsin,
where Black individuals account for less than seven per cent of the
population, the data show that they make up seventy-six per cent of
those incarcerated for felony murder. In St. Louis, every
felony-murder conviction between 2010 and 2022—a total of
forty-seven people, according to the State of Missouri—was of a
Black person.

To identify cases in other states, we worked with analysts at the
nonprofit organization Measures for Justice, and with several
law-school clinics, to obtain previously unpublished data. Thus far,
we’ve documented more than ten thousand felony-murder convictions
nationwide. We’ve also scoured trial records, appeals, and news
clips, finding and scrutinizing more than two hundred cases, like
Baxter’s, in which the defendant neither killed nor intended to kill
the victim. Women were sometimes charged for driving getaway cars for
abusive partners, or performing other tasks under duress; some of the
women served longer jail terms than their partners who’d committed
the killing. And, time and again, young people were prosecuted for
what an acquaintance, to their shock, had decided to do. In the past
two years, I travelled from Alabama to California to Michigan to meet
some of the individuals who have served time on the charge—along
with crime victims’ families, prosecutors, public defenders, and
others—to consider how a doctrine so widely critiqued, and rejected
elsewhere in the world, has proved stubbornly resilient in the United
States.

In the days after his arrest, Sadik Baxter figured he’d be released
on bail in time for his daughter’s first day of kindergarten. He’d
already bought Danasia’s uniform, a blue skirt and a bright-white
shirt. But, shortly after he learned that he was facing life in
prison, a nurse in the jail’s mental-health infirmary was wrapping
him in a “turtle suit,” a heavy anti-suicide smock, and a doctor
was prescribing a cocktail of drugs.

Once off suicide watch, Sadik remained in a spiritual hole. “I slept
through breakfast, lunch, and dinner,” he told me. The depression
lasted for most of his first year in jail, as he awaited trial. He had
originally been appointed a lawyer who struck him as attentive and
hardworking, but that attorney was soon replaced by another. The new
guy, Sadik thought, treated him like a nuisance. To soothe his panic,
he took to playing spades or dominoes with other men in the
infirmary’s dayroom. One afternoon, an older man named Erik came in
and asked for a word.

“Look, I can tell you’re fighting time, because I see you’ve got
stripes,” Erik said. Indeed, in the jail, inmates’ color-coded
outfits told a story, indicating the severity of charges. Men in black
and white stripes—including Erik—were staring down violent charges
that could carry a sentence of life. Sadik explained to Erik that he
was facing first-degree felony-murder charges for killing two people
he’d never encountered. “So why are you sitting around playing
spades,” Erik asked, “when you need to focus on learning the
law?”

Erik, a Detroit native, sat down with Sadik in his six-man cell and
pulled a manila envelope from beneath his bed. “Read this,” he
said, handing over a few pages of a lawsuit he had filed. Sadik had
never completed high school but considered himself a good
reader—he’d finished a dozen James Patterson novels in jail. He
found the language of Erik’s complaint baffling, though. The older
man assured him that he’d learn.

The jail had a law library, and Erik taught Sadik how to file a
request form that would grant him copies of a few cases at a time,
precedents that might prove relevant to his defense. Early each
morning, he’d head to Erik’s cell to read and annotate the cases,
turning one of the cots into his desk. Some of his spades partners
from the dayroom eventually joined him. “I’m all about freeing
myself,” Erik told them, “and you should be, too.”

The cell became a classroom, with Uncle E., as the men called their
new professor, using one wall as a chalkboard. Sadik told me that, in
addition to lessons on case research, “Erik taught us how to file a
lawsuit, how to write a grievance, and how to assert our
constitutional rights.”

Over the next two months, as Sadik burned through case files on felony
murder, a thirty-year-old opinion caught his attention. In State v.
Amaro, several men arranged to sell more than thirteen thousand
dollars’ worth of marijuana to a buyer, who, it turned out, was an
undercover cop. When other cops descended on the group, just after the
deal, to make arrests, Juan Amaro tried to escape by climbing a fence;
a detective grabbed him, pulled him to the ground, and hit him.
Moments later, one of his accomplices shot and killed an officer.
Could Amaro, who had been apprehended and struck just moments before
the officer was murdered, be prosecuted for the killing? “When I
read the case, my heart beat so fast,” Sadik told me.

On the fifth page of the opinion, the judge said that being arrested
didn’t relieve others of liability for the murder. But, in a
footnote, he qualified that his decision “_might_ have been
different” had a defendant been “securely in custody, either in a
jail cell, in a squad car, or perhaps even in handcuffs.” The judge
went on, “This is not the situation here, and, thus, is left for
another day.”

Sadik was ecstatic. He had been, indisputably, in handcuffs when the
deaths occurred. The judge’s phrase became a mantra of sorts, one he
often repeated in his cell when he felt hopeless: “Left for another
day!”

In the spring of 2014, as Sadik’s double-murder trial approached, he
and his attorney discussed the possibility of a plea deal. Should
Sadik agree to testify against O’Brian Oakley, his felony-murder
charges might be dropped, leaving only the thefts from five cars. Each
of those thefts carried a five-year maximum sentence, and his attorney
hinted that he might be able to negotiate that potential
twenty-five-year term down to less than five years.

One of Sadik’s cousins, Brian Kirlew, had been a public defender in
a nearby county, and wrote to urge him to take a deal: “I have tried
7 murder cases and nearly 50 jury trials. I am as experienced and
competent as a trial lawyer gets. So listen to me carefully: You need
to take a plea deal, if you want to get out of prison alive.”

Sadik didn’t want to snitch on a friend, though. And, while he would
readily acknowledge the burglaries, he felt that he was innocent of
murder, and couldn’t imagine that a jury of his peers would
disagree. Even the judge, Jeffrey Levenson, had said at a pretrial
hearing, “I think you have a very defensible case, in terms of
whether you’re responsible for the homicide.” So in May, 2014,
Sadik shuffled into a Broward County courthouse in waist chains,
changed into the black suit that he’d worn to his mother’s
funeral, and girded himself for a trial.

Before swearing in the jury, the judge offered Sadik a final chance to
take a plea, and underlined the risk. “Jury instructions in this are
pretty tough for a defendant,” he explained, and if Sadik were to be
convicted he’d be forced to sentence him, under mandatory sentencing
rules, to life in prison.

Florida—where our investigation discovered nearly a thousand people
serving life or life without parole for felony murder—is one of more
than twenty states in which the law routinely strips judges of their
discretion in sentencing those convicted on the charge. In many cases,
a judge’s only option is mandatory life.

Sadik’s lawyer and the prosecutor scrambled unsuccessfully to settle
on a plea deal, and Sadik duly took his seat at the front of the
courtroom, his brother and sister filing in behind him. Friends and
relatives of the victims had filed in, too, and, in a trial that
lasted just two days, several witnesses took the stand to recall the
last moments in the lives of Christopher McConnell and Dean Amelkin.

James Bolger had biked with the two men every Sunday morning for
years. On that final morning, Bolger told the courtroom, he’d been
approaching a green light, trying to catch up with McConnell and
Amelkin, who were riding ahead of him. Suddenly, Bolger testified,
“there was a silver blur of a car going through, and they were
gone.” Bolger, a trained paramedic, raced over. “And what did you
see?” the prosecutor asked. “There wasn’t anything to be
done,” Bolger replied. The men’s severed limbs were strewn in
multiple directions.

Although the testimony was devastating to McConnell’s wife, Denise,
she told me that, at the time, she had found comfort in the
felony-murder doctrine, sensing its moral solidity. She had married
her husband when she was twenty-one, and he’d been her stabilizing
force. They’d raised a family and run an air-conditioning company
together, and his death, she said, had put her “through hell.”
Listening to the evidence, she had concluded that the defendant had
decided to steal and dragged his friend into it, so why shouldn’t he
be held accountable for the ramifications? No one mentioned that, if
convicted, Sadik Baxter would get life in prison—a prospect that
later disturbed her.

After the prosecutor called more than a dozen witnesses, including
Bradley Kantor, the man from whom Sadik had stolen the sunglasses and
loose change, Sadik’s attorney called just one: Sadik himself, who
was nervous and struggled to speak clearly. He confessed to the
thefts, hoping that the jury would value his willingness to take
responsibility. When Sadik finished and returned to his seat,
O’Brian Oakley’s attorney shook his head and said, “You
dumbshit! You just convicted yourself.” It took the jury
thirty-seven minutes to reach a verdict. On both counts, Sadik was
guilty of first-degree murder.

Ian Marcus Amelkin, back in Brooklyn, was shocked to get a call from
the state’s attorney’s office telling him the trial was over less
than forty-eight hours after it had begun. Hanging up, he felt his
grief compounding. He’d spent two years consumed by postmortem
logistics—reminding his mom to eat, settling Dean’s debts—while
also wrecked by his own memories: Dean’s “Wayne’s World”
impressions; his turning the volume up high for everything Jimi
Hendrix, whom he’d seen in concert on New Year’s Day in 1969; his
lessons, as a meat man, on how to grill the perfect steak. And now
Dean’s death was being used by the state to separate someone
else’s father from his child.

“Another life is ruined,” Ian wrote flatly to his family in an
e-mail. He’d recently forsaken corporate law to become a public
defender (“Would you really leave all that money on the table?”
his dad had wondered shortly before he died), and the brevity of Sadik
Baxter’s trial made him wonder if a real defense had even been
mounted. He called his sisters, Brett and Chelsey, to ask what, at
this point, the three of them might do.

Ian had attended New York University School of Law, where he joined a
clinic run by the Alabama civil-rights lawyer Bryan Stevenson.
(“That was back when he was legal-nerd famous, not Oprah famous,”
Ian said.) At the time, Stevenson was preparing to litigate a
groundbreaking felony-murder case before the Supreme Court: that of a
fourteen-year-old who had been sentenced to life in prison for a
killing done by one of his companions. That case contributed to the
Court’s declaring that mandatory life-without-parole sentences for
juveniles were unconstitutional. Ian was assigned to work with one of
Stevenson’s death-row clients, a case that immersed him in his
professor’s contention that “each person is more than the worst
thing they’ve ever done.”

From the beginning, Ian had tried to apply that same perspective to
Sadik Baxter and O’Brian Oakley, and when he and his sisters learned
that the two men would be charged with double murder in the first
degree, they also sensed, as Brett put it, that “Dad would think
it’s bullshit.” Knowing that the State of Florida gives special
weight to crime victims’ perspectives, Ian decided to try to
persuade the prosecutor to dismiss the murder charges. “I didn’t
go in with an abolitionist perspective,” he recalled. “A
reasonable sentence would have been fine with us”—say, a maximum
of ten years for Oakley and a few years for Baxter.

In a phone call with the prosecutor, the champion debater tried to be
chummy and measured as he suggested that, after an accident, locking
up two young fathers (Oakley had a daughter, too) for lengthy terms
wasn’t his family’s idea of justice. His arguments failed to land,
and, Ian told me, the prosecutor later called to float the idea of
Oakley’s pleading to forty years. “Very, very harsh,” Ian
exclaimed, growing frustrated. Afterward, he swung between anger at a
prosecutor who seemed to want him to be “out for blood” and guilt
that he’d let Baxter and Oakley down.

With Baxter’s verdict now in, Chelsey contacted his lawyer to ask if
she and her siblings might help at sentencing. The attorney was
stunned—it was the first time that a family of a crime victim had
reached out in this way to help one of his clients. Although
Baxter’s sentence was pretty much a foregone conclusion, the lawyer
thought the fact that Dean’s kids were asking for restraint
couldn’t hurt. It might even help someday, the Amelkins figured,
should Baxter appeal.

In early June, 2014, when Sadik returned to court to be sentenced, his
lawyer approached the bench, holding aloft the Amelkin siblings’
plea for mercy. It argued that Sadik had been in handcuffs when the
chase began and that a life sentence without parole would be “cruel
and unusual punishment” and leave them “heartsick.” After
acknowledging the missive and calling Sadik forward to read a letter
of apology, Judge Levenson decreed the inevitable: life without
parole. “The law in itself, good, bad, or indifferent, is enacted by
the legislature,” Levenson said, concluding, “Good luck to you,
Mr. Baxter.”

The man who killed Donna Amelkin’s first husband got nine months.
The man whose friend killed her second husband got life without
parole. As “nuts” as the discrepancy seemed to her, she told me,
she hadn’t lost much sleep over it. (Either way, she said, “I’m
still the one who’s left alone.”) She had been more preoccupied by
a different injustice: that the felony-murder rule was being used to
obscure the role that the Broward County Sheriff’s Office had played
in Dean’s death.

Donna ran a high-school English department, and while sitting shivah
she’d received a letter from the husband of a former co-worker. A
former law-enforcement official in South Florida, he’d enclosed a
copy of the county sheriff’s policy on high-speed chases, with key
phrases highlighted. Deputies were barred from starting hot pursuits
if the suspects weren’t immediately endangering other people’s
lives or engaged in a “forcible felony,” such as a rape, a murder,
or a home invasion. Such policies exist for a reason: high-speed
law-enforcement chases are often lethal, causing roughly one death per
day in the U.S., according to a 2017 report by the Bureau of Justice
Statistics. The Amelkins began asking why Baxter’s thefts had
necessitated such a chase, upon which the sheriff denied that a chase
had even occurred. In 2014, the family filed a wrongful-death claim
against the sheriff’s office and reached a settlement that came with
no admission of fault.

Felony murder “made it easier for the sheriff’s department not to
take responsibility,” Donna told me. Once Baxter and Oakley were
charged with murder, she said, “the question of how the deaths
happened got pushed aside.”

In our reporting lab, we identified more than thirty instances of
high-speed law-enforcement chases that resulted in fatalities and were
followed by a felony-murder charge. In some of these cases, police had
violated their own pursuit policies.

Another subset of felony-murder cases we examined involved shootings
by people in law enforcement. In many states, when an officer fires a
lethal gunshot at a crime scene, individuals who were with the victim
may be charged with the killing. (The rationale is that, without the
instigating felony, police wouldn’t have been on the scene in the
first place.) We compiled twenty cases in which an officer pulled the
trigger and someone else assumed the charge; the best known of these
cases is that of LaKeith Smith.

In 2015, when he was fifteen, LaKeith and four friends broke into two
unoccupied homes in Millbrook, Alabama, to steal Xbox games and other
electronics. A neighbor called the police, who appeared, guns drawn.
LaKeith ran into the woods, and one of the officers shot and killed
his friend, sixteen-year-old A’Donte Washington, who they said had a
gun. The prosecution alleged that one of the older teen-agers had
fired a shot, and a grand jury found that the officer’s use of force
was “justified.” LaKeith was charged as an adult with murder, for
the killing at the officer’s hand.

Reviewing our felony-murder data, which included more than a thousand
cases involving teens like LaKeith, my lab colleagues and I were
struck by a contradiction. The Supreme Court has acknowledged that
adolescence is marked by “a lack of maturity and an underdeveloped
sense of responsibility,” which make juveniles “less deserving of
the most severe punishments.” But when it comes to felony murder, we
discovered, being younger was not a mitigating variable. The average
age of individuals convicted of felony murder appeared to be lower
than for standard murder—in many states, more than four years lower.

[In prison Baxter developed a mastery of felonymurder jurisprudence
which surpassed that of many professional defense...]

In prison, Baxter developed a mastery of felony-murder jurisprudence
which surpassed that of many professional defense attorneys.Photograph
courtesy the author

Jenny Egan, the chief attorney for the juvenile division of the public
defender’s office in Baltimore, told me, “Because of peer
pressure, young people tend to commit crimes in groups,” and, when a
death results, “all of the kids involved get charged with murder,
and it gets used as a cudgel to get kids to coöperate against each
other.” Nazgol Ghandnoosh, the co-director of research at the
Sentencing Project, notes that youth of color are particularly likely
to be “punished for presence.”

LaKeith watched as, one by one, his friends took pleas that ranged
from seventeen to twenty-eight years. But LaKeith and his family, some
of whom knew firsthand how violent the state’s prison system could
be, decided to take his case to trial. In 2018, LaKeith, who is Black,
was sentenced before an all-white jury to sixty-five years in prison,
later reduced to fifty-five years. “There’s no sugar-coating
it,” LaKeith’s mother, BronTina Smith, told me. “He was punished
for bucking the system and trying to exercise his right to a trial.”

BronTina has since become a prominent voice in a movement to challenge
the felony-murder rule—a movement led for many years by families of
incarcerated people and lately galvanized by Black Lives Matter.
BronTina works with a coalition spearheaded by Represent Justice, a
nonprofit organization, and together they persuaded celebrities from
Erykah Badu to Kim Kardashian to direct attention to LaKeith’s case.
One of the coalition’s goals is to lobby for state reforms that
would limit how the felony-murder charge can be used against
defendants who didn’t actually kill, including those held
responsible for shootings by law enforcement.

Marshan Allen, a Represent Justice staffer who canvassed Millbrook
residents on the issue at bars and tailgates, said, “We spoke to a
lot of very conservative people, and most of them had no idea how this
law works. But, once we explained it to them, we found that they
didn’t agree with LaKeith’s sentence at all. It’s intuitive.
People get it.”

Last December, under pressure, the judge who’d originally sentenced
LaKeith to sixty-five years agreed to a resentencing hearing. “GOD
IS REAL!!!!!” his mother posted online. In court, the civil-rights
lawyer Leroy Maxwell would have a chance to make the case that
LaKeith’s original public defender had neglected to present
mitigating evidence. Maxwell hoped that his client might be
resentenced to time served, and walk free.

Last March, on the night before the hearing, LaKeith’s supporters
held a vigil in Montgomery. While making posters to take to court, his
family chatted about the meal they’d serve when he came home.
“Greens and chicken and mac and cheese—all the soul food,”
BronTina said, smiling. “Cereal,” countered LaKeith’s aunt
Gladys, remembering how the boy would come to her house “and
suddenly all of my Cinnamon Toast Crunch and Frosted Flakes would be
gone.”

The next morning, LaKeith—now a twenty-four-year-old who’d spent a
third of his life behind bars—entered a courthouse in Wetumpka,
Alabama, in orange shower shoes and chains. His mom, in sparkly green
sneakers and a fedora, sat in the first row. Judge Sibley Reynolds
listened to a series of witnesses, including A’Donte Washington’s
father, who testified that he hadn’t been called at the original
trial. What he would have said, he told the judge, was that LaKeith
shouldn’t serve time, because “he wasn’t the one that murdered
my son.” Even the D.A. appeared receptive to a lighter sentence,
saying of the original attorney, “Hell, I wouldn’t hire her!”

Finally, the judge looked down at LaKeith. “I’m sentencing you to
thirty years in custody,” he said. Many people in the gallery
gasped. “Dirty bigot judge!” a woman behind me shouted.
“The _cops_ killed A’Donte!” That night, the homecoming feast
that the Smiths had optimistically prepared was used to feed a tearful
group.

Because Florida is one of many states where what begins as a visible
first-degree felony-murder charge in the data gets mysteriously
truncated, after conviction, into first-degree murder, Sadik Baxter
was now, to the system, just another killer—a wary lifer who passed
the years performing prison jobs with antebellum-sounding names, like
“houseman” and “groundsman.” But, on his own time, Sadik had
channelled his inner Uncle E. and evolved into a jailhouse lawyer
whose mastery of felony murder surpassed that of many professional
defense attorneys. Three filing boxes of annotated case law were among
his most valued possessions; he carted them from prison to prison over
the years.

He’d come to believe that one of the most promising defenses in his
case was the “independent act” theory, which had received passing
mention in State v. Amaro. It established that a defendant wasn’t
responsible for an illegal act by his “co-felon” if that act was
committed after, and apart from, the original felony. Sadik believed
that O’Brian’s fatal police chase, having come after his own
arrest, was an independent act. He just needed to prove it to a judge.

On good days, he hunkered down with a copy of “The Jailhouse
Lawyer’s Handbook,” sixth edition, and wrote and rewrote his
pro-se legal briefs, Jamaican dancehall music blasting in his
earphones. On days when the fight seemed hopeless, he turned to
“Conversations with Myself,” by Nelson Mandela. “At least, if
for nothing else,” Mandela had written in a letter from Robben
Island, “the cell gives you the opportunity to look daily into your
entire conduct, to overcome the bad and develop whatever is good in
you.” Mandela turned to meditation, dream journaling, and letter
writing. Sadik took up all three.

A particular obsession was imagining his way into the life of his
daughter, Danasia. If he couldn’t join her at her basketball games,
he could at least commune with her in his manifestation journal, where
he would articulate his wishes for her future as if they had already
happened. One day, having heard that she was selling lip gloss, he’d
written, “Danasia’s lip gloss company has sky rocketed in sales
and is the most popular lip gloss company in the world. It is
currently net worth 7 million dollars between the 7 stores she owns
and is climbing by the day.”

Danasia was now a teen-ager. Sadik had been filing motions and appeals
since she was in the first grade. As he discovered, litigation is a
waiting game; years could pass between a petition and a ruling. He
tried arguing that he’d had ineffective representation, and that the
sharing of sixty-nine “gruesome” photographs of the victims’
body parts and a bloody crime scene had biased the jury. He tried to
get his sentence reduced, appealing to “the mercy of this court”
to convert his charge to manslaughter; in May, 2018, the court
replied: “_denied_.” In 2019, he filed a motion for
post-conviction relief (“_denied_”), and in 2020 a motion for a
rehearing (“_denied_”). In 2021, he ventured a Motion to Correct
Illegal Sentence (“_denied_”).

Sadik also wrote to half a dozen journalists, and to more than twenty
law-school clinics and civil-rights attorneys around the country. In a
letter to then President Barack Obama, he explained that he’d faced
discrimination in court because of his race and his poverty, and
concluded, “I humbly ask you to point me in the right direction to
help me with my case.” These efforts came to nothing.

Elsewhere in Florida, in another prison cell, his co-defendant,
O’Brian Oakley, was waging a similar battle. O’Brian had been
convicted on even more grounds than Sadik, including two counts of
first-degree felony murder and two counts of vehicular homicide, as
well as five counts of burglary. (The court was evidently unmoved by
another of Ian Marcus Amelkin’s letters: “Now four lives—my
dad’s, Mr. McConnell’s, Mr. Baxter’s, and Mr. Oakley’s—are
forever destroyed by the events of August 5, 2012. . . .”)

O’Brian appealed: How could he be guilty of four counts of murder
when only two deaths had occurred? In 2018, an appellate court agreed
and dropped his two vehicular-homicide convictions. But the mandatory
sentence—life without parole—remained.

When I spoke to O’Brian last spring, he wept throughout the
conversation. “People lost their lives, and I have to live with
that,” he told me, describing how often he replays the scene of the
accident, and his panicked decision to flee. “Every day, I wake up
and realize that I feel pain even in my dreams,” he said. Before his
incarceration, lyrics and musical ideas came easily to him. “But
I’ll try to write a song now and I can’t finish it,” he said.
“I try to sing, but with the pain I can’t.”

By the fall of 2021, Sadik’s options for appeal in Florida were
dwindling and he realized that he had one real hope left: a federal
claim. He’d already argued that his life sentence was “repugnant
to the Due Process Clause of the Fourteenth Amendment,” because
discretion in sentencing is a paramount function of the judicial
system, and the judge in his case had been stripped of it. Now, citing
the “independent act” doctrine and State v. Amaro, he would make a
key assertion—that his life sentence was an “unreasonable
application of established federal law,” reflecting the kind of
“grossly disproportionate” sentencing that is prohibited by the
Eighth Amendment.

Not long after Sadik filed his argument, I happened to write to him
for the first time, requesting an interview. His response to my letter
came almost immediately: “I must say this still feels surreal, as
for years I’ve been searching for a listening ear to hear the
corruption and injustice in my case, or even to be acknowledged as a
human being.” Soon, we were talking almost daily.

One night in April, Sadik called, anxious. He believed the federal
judge would be ruling soon, and asked, “Have there been any updates
in my case?” Not having a lawyer put him at a serious disadvantage;
it often took weeks for him to receive basic updates from the court,
even on time-sensitive matters.

I logged into _pacer_, a federal-records database, and there it was:
a ruling from U.S. District Judge Beth Bloom. I downloaded the file,
quickly scrolled to the bottom to find the judge’s decision on his
habeas petition, and read it aloud: “_denied_.” Then I read more
closely, and said, “Hold on.”

The judge had rejected the appeal on thirteen grounds. Her reasoning
turned on a little-known but extraordinarily consequential law, the
Antiterrorism and Effective Death Penalty Act of 1996. Signed by
President Bill Clinton, the law radically curtails the rights of
incarcerated people. Even if Judge Bloom agreed that Sadik was in
prison unconstitutionally, she’d have to defer to the Florida court,
unless a very narrow set of conditions could be met. The surprise in
the ruling came on the ninth page, when she took up Sadik’s Eighth
Amendment claim.

“The court agrees that the life sentences in this case were
harsh,” she wrote. She later quoted a sentencing statement from
Judge Levenson in 2014, acknowledging that the defendant had had
little to do with the two bicyclists’ deaths: “Notwithstanding
your involvement in the case, which I think we all agree was not a
significant involvement, I am mandated to sentence you to life in
prison.” On Eighth Amendment grounds, Judge Bloom had decided to
grant Sadik’s case a precious “certificate of appealability,”
allowing him to present his argument to a higher court. Over the
phone, he exclaimed, “I’m not fully dead!”

Although defenders of felony murder often cite its value as a
deterrent, none of those I interviewed who had been imprisoned for the
crime, including Sadik, knew of the statute before being charged with
it. In 2021, a task force commissioned by the Minnesota legislature
further explored such questions of deterrence. This inquiry was
spurred largely by two mothers, Toni Cater and Linda Martinson, whose
daughters were serving time on the charge after a man they’d met
only minutes earlier shot and killed someone.

Upon analyzing state data and reviewing empirical research, the task
force concluded that the felony-murder charge “does not deter
behavior” and “does not reduce the risk of re-offense.” What’s
more, it intensified inequities. A Black person in Minnesota was five
times more likely to be charged with felony murder than a white
person, and a Native American person ten times more likely. Fully a
third of those locked up for murder in the state were in for felony
murder, and most of them had no prior conviction for “an offense
against a person.” This spring, the legislature decided to curtail
severe sentences and limit the future use of the felony-murder charge
for defendants who did not commit a killing. Because the reform will
apply retroactively, hundreds of people, including the daughters of
Cater and Martinson, may have a chance to win relief.

Minnesota legislators took their cues from California, where, after
groundbreaking reforms, more than six hundred people have had their
sentences reduced and, according to a study by California’s Office
of the State Public Defender, taxpayers have saved as much as $1.2
billion in prison costs. Illinois and Colorado have also recently
narrowed the use of the felony-murder doctrine, and a bill now pending
in New York would permit the use of the felony-murder charge only if a
defendant “directly caused the death recklessly” or served as
“an accomplice . . . in the felony, and acted with the intent to
cause death.”

But, as some states pull back from the concept, others are expanding
it. In Arkansas, legislators have considered a bill allowing district
attorneys to charge women who obtain unauthorized abortions, and
anyone who aids them, with felony murder. (In the Dobbs decision,
Justice Samuel Alito wrote that abortion offered America its
“proto-felony-murder rule”; in the colonies, if a doctor gave a
pregnant woman a “potion” to aid in an abortion and she died, he
could be charged with murder.) In the wake of Dobbs, other states have
proposed legislation similar to the Arkansas bill. Some legislators
are also pushing felony murder’s expansion into another fraught
terrain: overdoses tied to the opioid epidemic.

“These cartel bosses, who have taken advantage of the weakness of
the Biden Administration, must be held accountable for the millions of
lives they have destroyed with this horrific drug,” Senator Ted Cruz
said recently, in support of a bill to make the lethal distribution of
fentanyl punishable with federal felony-murder charges. A mere two
milligrams of the synthetic opioid, which is cheaper than heroin and
is often used as a filler by underground drug producers, can be a
lethal dose. As deaths of unsuspecting users soar, red-state
politicians have rallied around this cause.

Some defenders and prosecutors argue that this hard line will lead to
more deaths, as fellow-users hesitate to dial 911 when they witness an
overdose. But proponents underline a payoff: that felony-murder
prosecutions will bring down drug kingpins and major suppliers.

When I examined more than three dozen overdose-related felony-murder
prosecutions, I didn’t find kingpins. What I found instead were
defendants like Jacob Sayre, of Ozark, Missouri. Last December, when
he was seventeen, he was charged with killing a sixteen-year-old girl,
Victoria Jones, whom he’d met at church.

One night in September, 2022, Jacob, a homeschooled kid whose mom
helped run a Bible-study group, had received a Snapchat message from
Victoria, a softball whiz who was also a gifted student. (“She was
headstrong in science,” her father told me.) According to the
probable-cause statement, Victoria wanted Jacob to bring her some
cocaine, but his dealer didn’t have any. Jacob gave her a Percocet
instead. “Only do a quarter and then do the other quarter if you
don’t feel it,” he messaged. “Please be smart.”

Victoria locked the door to her bedroom, on whose wall hung a periodic
table she knew by heart. Not long afterward, she messaged Jacob,
“Ok, I took it, like a 3rd, fucking cut it wrong, holy duck, I feel
it.” The next morning, her dad forced open her door with a
screwdriver. Victoria was dead, and on the nightstand was a rolled-up
twenty and the remains of a small blue pill.

Shortly afterward, Jacob, who had never before been in trouble with
the law, was charged as an adult with felony murder and other
offenses. “Her loss affected the whole community, and we are one
hundred per cent in agreement with the state,” Victoria’s father,
David Jones, told me. “We don’t believe a felony-murder charge is
overreach.”

When Jacob and I spoke this summer, he was on house arrest, trying to
keep calm as he awaits trial by practicing Van Halen covers on his
guitar. His mom, meanwhile, conducts ongoing imaginary conversations
with the district attorney: “So when you charge Jacob, and you put
him in prison, does that make our society any safer?”

Joshua Elbaz, of Gwinnett County, Georgia, is well positioned to
understand the urges for both retribution and mercy. When he was
twenty-one, his older brother, Brenden, died of a heroin overdose. In
2018, Joshua went to law school, imagining that he’d become a
defender and try to guide people who were battling addiction toward
help, not prison time. But in February, 2020, while he was in class,
his dad called, and called again. His younger brother, Alex, was just
two months away from earning his accounting degree when a Percocet
laced with fentanyl killed him.

This time, Joshua became obsessed with tracking down the man he called
“my brother’s murderer.” The attitude of the local police being,
as he put it, “Tough shit, get over it, there’s no case,” he
investigated on his own. Alex’s Samsung watch contained copies of
his text messages, which identified a landscaper named Phillip
Patterson as the person from whom he had last bought drugs. Patterson
was soon arrested in a sting.

Upon graduating from law school, Joshua joined the Gwinnett County
district attorney’s office as a prosecutor. The office helped bring
four felony-murder cases against dealers, and, while he didn’t
formally work on Patterson’s case, he said, “I was so angry. I’d
say, ‘I’m going to take that man to trial, and I hope he gets
life.’ ” In early 2023, three years after his younger brother’s
death, he was in the courtroom for Patterson’s pretrial hearing.

Like many people accused of felony murder, Patterson had taken a plea,
conceding to voluntary manslaughter and drug trafficking in exchange
for a forty-year sentence, with the possibility of parole after
thirty. In court, Patterson read a letter of apology to the Elbaz
family as tears streamed down his face. “He said, ‘I really
didn’t know the drugs were laced,’ ” Joshua remembered, “and
I believed him.”

Joshua was struck by something else he’d learned in court: that
Patterson had suddenly stopped attending his family’s Sunday dinner,
which had later seemed like a clue that he was suffering from
addiction. “When I heard that,” Joshua said, “the most human
part of me thought, That’s the exact same thing that happened to
Alex. He just stopped coming to Sunday dinner.”

Although he still believes that dealers who intentionally sell
fentanyl-laced pills should be liable for murder, Joshua now thinks
that murder charges against those who are struggling with addiction
themselves won’t touch the root causes of the crisis. And, as much
as he’d dreamed of seeing Patterson led off in shackles, when it
actually happened, he told me, “it hit me like a train.”

Sadik is now incarcerated in the Okaloosa Correctional Institution, in
the Florida Panhandle, hours from where most of his family lives. One
recent Saturday morning, I joined a line of women holding special
transparent purses they’d bought to allow them to carry money for
snacks through the prison gates. Inside, I spotted Sadik instantly.
Living up to his mom’s nickname, Coconut Tree, he stood even taller
than the two palms painted on a prison wall—part of a beach scene
where loved ones could pay to get their photo taken. “I’m
nervous,” he said. He hadn’t had a visitor in five years, when
Danasia had last come with her mom and his sister.

Sadik remembers every detail of that encounter: how Danasia covered
her face when she arrived; how he’d coaxed her forward by singing
“Gon’ Get Better,” by the Jamaican artist Vybz Kartel; how, when
he’d finished, she’d asked him to sing it again until, finally, he
protested, “You sing _me_ a song!” For the next five hours,
they’d played Life and Connect Four at a picnic table, and when
visiting hours were up they had both cried. In the following years,
his efforts to sing his way into her affections grew less successful.
“She’s, like, ‘Daddy, I’m fifteen now, I don’t watch
“Strawberry Shortcake” anymore,’ ” he told me. Recently, she
had been missing his calls altogether.

He was telling me this as we sat in the stupefying heat of the prison
yard—a spot that afforded us some privacy from guards who called him
Too Tall and Sasquatch. Sadik was eating a box of fruit snacks from
the canteen which looked to me like processed plastic but reminded him
of the Jamaican fruits that had led him to God. He wanted to know what
I’d learned from other families fighting for felony-murder-law
reform, and when I left he asked me to tell him something of the
natural world outside the prison walls. That evening, I went for a
swim at a nearby beach and sent him a photo of a waning moon over the
water.

Once home, I would check _pacer_ for updates on his federal case,
and one afternoon I found a startling posting: the court would toss
out his petition if he didn’t reply within fourteen days. He’d
made a mundane filing error but had yet to receive a copy of this
notification himself, and had only a matter of days left to sort it
out. I called a lawyer who I thought might help me find someone to
translate the court’s almost incomprehensible instructions. He
described the case to Christine Monta, an appellate attorney at the
MacArthur Justice Center, who felt stunned when she looked it up. This
was the kind of legal challenge to felony murder, she told me, that
she had longed for years to take on.

Sadik Baxter’s case, she said, represented a chance to challenge the
“triple injustice” that many people incarcerated in state prisons
have experienced. First, prosecutors hit them with charges, like
felony murder, that are disproportionate to their crimes. Second,
because of mandatory sentences, defendants get “extreme,
unconstitutional sentences.” And, third, because of the
Antiterrorism and Effective Death Penalty Act, they are hindered from
bringing their claims to federal court. To prevail, they typically
have to identify either a significant and indisputable factual error
made by a state court or a preëxisting Supreme Court case that
clearly backs up their argument. “Congress has erected this very,
very difficult standard, but we really think he meets it,” Monta
told me. As a number of Supreme Court precedents have established, she
went on, “punishment should not be vastly disproportionate to your
culpability, and everyone agrees that culpability for murder here is
really, really strained.”

With Sadik’s permission, she began to craft a habeas appeal on his
behalf. She hopes to argue in federal court that his mandatory
life-without-parole sentence is unconstitutional and that his case
should be remanded back to trial court for resentencing.

Not long ago, while assembling the case, she encountered an intriguing
relic: the impassioned letter by Ian, Brett, and Chelsey Amelkin
arguing that Sadik’s sentence was cruel and unusual, which had been
omitted from his official post-conviction court record. Moved by this
lost document, she sat at a desk lit by her own late father’s lamp
and began to type the outlines of an argument.

Could former President Trump be prosecuted for felony murder for
urging on the January 6th attack on the U.S. Capitol, which led to a
number of deaths? Could fossil-fuel-company executives be held liable
for murder for criminally deceiving the public about carbon emissions
that killed people? If we take the felony-murder doctrine’s core
premise seriously, it’s easy to imagine a radically different
justice system. But, after two years of closely reviewing cases, I can
state with confidence that the doctrine is rarely levelled against
people of influence. It is used instead to impose some of our
society’s harshest punishments on low-income defendants, young
people, and defendants of color.

I was reminded of this imbalance when I tried to reach out to Bradley
Kantor, who had called the police when Sadik stole the loose change
and sunglasses from his car. Searching online, I learned that two
years ago Kantor had been arrested in a federal raid. He pleaded
guilty to conspiracy to commit forty-two million dollars’ worth of
health-care fraud and conspiracy to commit money laundering. He was
sentenced to a decade in prison, and the government seized his
multimillion-dollar home, his two Winnebagos, and his
thirty-seven-foot yacht. When I shared this news with Ian recently, we
decided we were looking at a parable of American sentencing: Sadik
Baxter stole a few dollars, a drum set, some used baseball equipment,
and a pair of sunglasses and got life, while Bradley Kantor stole
millions and got ten years.

Brett and Chelsey Amelkin are now, like their brother, public
defenders. When they heard the news of Sadik’s momentum in his
federal case, all three siblings felt heartened. “He deserves a
shot,” Ian said, “and so does Oakley.” If Sadik gets his second
chance, Ian has already pictured the scene. Before showing up at the
hearing, he’ll play the music Dean loved—Hendrix, Led Zeppelin,
Blind Faith—and grab from his closet a striped tie of his dad’s
that he thinks brings him luck in court. “It’s all fucked up,”
he said of the tie, grinning, as he laid it out for me. “I tape it
together when I wear it.”

This fall, Sadik was placed in solitary confinement after a dispute
with a guard. In a cell whose window was covered over by aluminum, his
mind kept turning to Lolita, an orca at the Miami Seaquarium he’d
loved to visit as a child. When young, she’d been taken from her
home in the Salish Sea, north of Seattle, and spent the next fifty
years penned in the Seaquarium. Indigenous activists, many of whom
knew her as Tokitae, had recently won a multi-year battle to bring her
home. But, just before Sadik was put in solitary, she died, still in
captivity.

Less morose distraction could be found in his manifestation journal.
When the broader public learned the details of his case, he wrote one
day, “it was such a shock to everyone that they changed the Law.”
When he was finally released from solitary, he called Danasia, eager
to tell her how real this vision had seemed. She picked up for the
first time since May.

“I still want to take you to all the places you asked me to take you
when you were younger—the water park, Disney World, the beach,” he
said. She grew quiet, and then had to go, but the conversation
continued in his head. “I want to take you to my daddy’s farm and
show you the apple trees, and the jackfruit trees, and the mango
trees. I’ll show you how to chop the sugarcane. And I’ll show you
how to take the bamboo and use it to make a kind of slingshot, so that
you can place an apple blossom inside it, and let it fly.” 

_Sarah Stillman is a staff writer at The New Yorker. She teaches
investigative reporting at Yale, and created the Global Migration
Project at Columbia University’s Graduate School of Journalism._

_Baji Tumendemberel, Thomas Birmingham, Scott Hechinger, and Khue Tran
contributed data gathering and analysis, as part of the Felony Murder
Reporting Project [[link removed]]._

* Mass Incarceration
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