## Facts

- Heflin Mack Langford drove on a four-lane highway in Montgomery County, Alabama.
- His vehicle struck a mileage marker, swerved left, crossed the median, and collided with an oncoming car driven by sixteen-year-old Randall Holt, killing Holt instantly.
- Witnesses reported smelling alcohol on Langford’s breath; testing showed a blood-alcohol level of 0.25%.
- Witnesses also testified Langford was driving in excess of 90 miles per hour immediately before the collision.
- Langford testified he had consumed two beers, denied intoxication, and claimed mechanical steering problems caused the loss of control.
- The State charged Langford with first-degree murder on a “universal malice” / “depraved mind regardless of human life” theory, rather than a lesser homicide offense.

## Issues

1. Whether evidence of highly intoxicated, extremely high-speed driving causing a fatal collision is sufficient to sustain a conviction for first-degree murder under Alabama’s “universal malice” / “depraved mind regardless of human life” doctrine.

## Decision

- The Alabama Supreme Court reversed the judgment affirming Langford’s conviction and remanded.
- The court held the evidence was legally insufficient to support first-degree murder on a “universal malice” theory on these facts.
- The court indicated the evidence showed extreme recklessness and could support lesser homicide offenses, but it did not meet the heightened mental-state requirement for first-degree “universal malice” murder.

## Legal Principles

- First-degree “universal malice” murder requires proof of a “depraved mind regardless of human life,” reflecting a general and indiscriminate disregard for human life, not merely gross negligence or wantonness.
- Proof that a defendant drove while intoxicated at very high speed, without more, does not automatically establish the mental state required for first-degree “universal malice” murder.
- Where the evidence establishes extreme recklessness but does not establish “universal malice,” the appropriate grade of homicide is a lesser offense (such as second-degree murder or manslaughter), not first-degree “universal malice” murder.

## Conclusion

The Alabama Supreme Court set limits on applying first-degree “universal malice” murder to vehicular homicides, holding that even severe drunk driving and excessive speed causing death, without adequate proof of the statutory “depraved mind regardless of human life,” cannot sustain a first-degree murder conviction.


Langford v. State, 354 So. 2d 313 (Ala. 1977)