would now have both the intent to kill and the intent to destroy property. In contrast, where the defendant intends to kill one person but ends up killing another, there is still only one intent — the intent to kill. However, if the crime includes aggravating factors based on the victim's identity (such as a police officer, witness, or protected class), then the factors must be proven to have actually occurred in order to impose an enhanced sentence. For instance, if the defendant intends to kill a police officer in a jurisdiction where that is punishable by death, but instead kills a civilian, the death penalty may not be imposed unless there was another aggravating factor that actually occurred. The principle underlying the Unborn Victims of Violence Act of 2004 in the United States applies only to offenses over which the U.S. government has jurisdiction, namely crimes committed on federal properties, against certain federal officials and employees, and by members of the military, but treats the fetus as a separate person for the purposes of all levels of assault including murder and attempted murder: In the United Kingdom In the UK the transferred malice doctrine is not without controversy. The House of Lords in Attorney General's Reference No 3 of 1994 reversed the Court of Appeal decision (reported at (1996) 2 WLR 412), holding that the doctrine of transferred malice could not apply to convict an accused of murder when the defendant had stabbed a pregnant woman in the face, back and abdomen. Some days after she was released from hospital in an apparently stable condition, she went into labour and gave birth to a premature child, who died four months later. The child had been wounded in the original attack but the more substantial cause of death was her prematurity. It was argued that the fetus was part of the mother so that any intention to cause grievous bodily harm (GBH) to the mother was also an intent aimed at the fetus. Lord Mustill criticised the doctrine as having no sound intellectual basis, saying that it was related to the original concept of malice, i.e. that a wrongful act displayed a malevolence which could be attached to any adverse consequence, and this had long been out of date. Nevertheless, it would sometimes provide a justification to convict when that was a common sense outcome and so could sensibly be