Northington v. State, 413 So.2d 1169 (1981), was a case decided by the Court of Criminal Appeals of Alabama that reversed a conviction for murder on the basis that depraved heart murder requires a universal malice directed towards human life in general rather than malice directed towards a specific individual.Bonnie, R.J. et al. Criminal Law, Second Edition. Foundation Press, New York, NY: 2004, p. 799
