The Court quoted the Florida Supreme Court as saying that the interaction of the "felony murder rule and the law of principals combine to make a felon generally responsible for the lethal acts of his co-felon." Id

—his co-felons who are personally present. As perpetrators of the underlying felony, they are principals in the homicide. In Florida, as in the majority of jurisdictions, the felony murder rule and the law of principals combine to make a felon generally responsible for the lethal acts of his co-felon. Only if the felon is an accessory before the fact and not personally present does …

—"[t] he malice aforethought is supplied by the felony, and in this manner the rule is regarded as a constructive malice device."

Moreover, opinions issued shortly before and after Proffitt reveal a similar absence of comparative proportionality review.

—beating with a fire poker past the point of submission until the victim's body was grossly mangled is heinous

This is so because the felony murder rule and the law of principles combine to make a felon liable for the acts of his co-felons.

—of Florida rejected the "jury pardon" concept, at least as it pertains to the various degrees of homicide under category one of Brown.

—explained that "liability is circumscribed by the limitation that the lethal act must be in furtherance or prosecution of the common design or unlawful act the parties set out to accomplish." Also,

[PDF] Supreme Court of Florida