State v. McCovey

In State v. McCovey, 803 P.2d 1234, 1238 (Utah 1990) the Court stated that "the traditional common law purpose of the felony murder doctrine has been to allow the State to obtain a second degree murder conviction without proving any form of mens rea, or mental state." The court further stated that felony murder is, "in essence, . . . a strict liability offense." Id. In the same paragraph the court indicated that the required mens rea was not the mental state regarding whether the felon intended to commit murder. Id.