nd possibly wounded Heanes as well cannot be precisely determined, Newton would be convicted for Frey's murder. His conviction would be subsequently overturned on several grounds, most notably that the jury had not been instructed on involuntary manslaughter.
An involuntary manslaughter instruction was deemed necessary because Newton's lawyers argued he could have been suffering from neurogenic shock because of the amount of blood he had lost from his gunshot wound. Consequently, he could not form the requisite intent to murder Frey. Although, Newton's conviction was overturned and two subsequent re-trials ended in hung juries, Newton would often boast that he had indeed shot Frey. There is no evidence throughout the book that any Panther member or affiliate ever held Newton personally or morally responsible for Frey's death. In fact, journalist Peter Solomon described the public feeling about Newton's release when the conviction was overturned as "like one massive orgasm."
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