I guess none of you have seen Law and Order?
How she died, whether it was due to OD'ing or at the hands of Craig/Kelly/Anthony Gross, remains to be seen. But, in order for someone to die from strangulation- and having a white curtain as the device used during the strangulation- that means that you had time to think about the events as they developed.
It's not like she was the one that jumped into the curtain and killed herself...though anything at this point in time remains to be seen.
There is also rumor (last "update" I heard anyhow) that she could have possibly still been alive when the car was lit on fire. In that instance, it would certainly lead to Murder One.
Then again, I'm no lawyer, just watch Law and Order with McCoy Inc...