Lewis v. State
474 So. 2d 766 (1985)
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Rule of Law:
A defendant's conduct is not the legal cause of a death if the victim's subsequent act of free will constitutes a supervening, intervening cause that breaks the chain of causation.
Facts:
- During the week before the victim's death, Alvin Ronald Lewis played Russian Roulette with his brother in the presence of the 15-year-old victim, Damon Sanders.
- During this earlier game, Lewis handed the gun to Sanders as part of the play.
- On May 30, 1983, Lewis and Sanders played Russian Roulette together again.
- After they finished playing the game, Lewis put the gun away in a closet.
- Later that evening, a witness saw Sanders sitting alone on a sofa in the living room, holding the gun and spinning its chamber.
- Shortly thereafter, while Lewis was in another room on the telephone, Sanders sustained a fatal, self-inflicted gunshot wound to the head.
- After discovering Sanders' body, Lewis moved it to a wooded area and disposed of a bloody towel and shirt before being persuaded to return the body and call the police.
Procedural Posture:
- Alvin Ronald Lewis was indicted for murder in a state trial court.
- At the close of the state's evidence during the trial, the judge granted Lewis's motion for a judgment of acquittal as to the charges of murder and manslaughter.
- The trial court submitted the case to the jury on the lesser included offense of criminally negligent homicide.
- The jury returned a verdict finding Lewis guilty of criminally negligent homicide.
- Lewis, as appellant, appealed his conviction to the Court of Criminal Appeals of Alabama.
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Issue:
Does a defendant's conduct of introducing and playing Russian Roulette with a victim constitute the proximate cause of the victim's death for the purposes of criminally negligent homicide, when the victim later, acting alone, retrieves the gun and shoots himself while playing the game?
Opinions:
Majority - Tyson, J.
No. The defendant's conduct was not the proximate cause of the victim's death. For criminal liability to attach, the defendant's conduct must be the cause-in-fact and the proximate cause of the death. Here, the victim's act of retrieving the gun and shooting himself was a product of his own free will. This act served as a supervening, intervening cause that was sufficient to break the chain of causation originating from the defendant's earlier conduct of teaching and playing the game with the victim. The court distinguished this situation from one where the defendant was present during the fatal act or had left the victim while the game was still in progress, in which case liability might attach. Because the defendant had put the gun away and was not present when the victim acted alone, the victim's conduct severed the causal link to the defendant's actions.
Analysis:
This case clarifies the limits of criminal liability for another person's self-destructive act by emphasizing the doctrine of supervening cause. The court's decision establishes that even when a defendant's conduct creates a dangerous situation or influences a victim, the victim's subsequent independent and voluntary act can absolve the defendant of criminal responsibility for the resulting death. This holding makes it more difficult to secure convictions for criminally negligent homicide in cases where the victim's own 'free will' is the immediate cause of death. It reinforces the principle that criminal liability requires a direct and unbroken causal connection between the defendant's act and the resulting harm.
