People v. Acosta
169 Eng. Rep. 48 (1840)
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Rule of Law:
A defendant who sets in motion a chain of events with the intent to cause death is guilty of murder if the death is ultimately caused by an innocent or unconscious agent, as the agent's act is legally considered the act of the defendant.
Facts:
- Catherine Michael, the mother of a nine-month-old infant named George Michael, delivered about an ounce of laudanum, a deadly poison, to the infant's nurse, Sarah Stephens.
- Michael instructed Stephens to administer a teaspoonful of the laudanum to the infant each night, falsely claiming it was medicine.
- Michael's intent in providing the poison and instructions was to kill her infant son.
- Stephens, believing the child did not need medicine, decided not to administer the laudanum and left the bottle on a mantelpiece in her room.
- Several days later, Stephens' five-year-old son found the bottle of laudanum while Stephens was away from the home.
- The five-year-old boy administered a large dose of the laudanum to the infant, George Michael, causing his death.
Procedural Posture:
- Catherine Michael was indicted for the willful murder of her infant son, George Michael, at the Central Criminal Court.
- A trial was held, and the jury was given specific instructions on the law of causation and agency.
- The jury returned a verdict finding Michael guilty of murder.
- The trial judge postponed the final judgment to refer the legal question of whether Michael's actions constituted 'administering' poison to a panel of the senior Judges for their opinion.
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Issue:
Does a defendant 'administer' poison for the purposes of a murder indictment if they provide poison to an intermediary with instructions to give it to the victim, but that intermediary neglects to do so, and the poison is subsequently administered by an unconscious agent who discovers it?
Opinions:
Majority - The Judges (unanimous)
Yes, the defendant's actions constituted an administering of poison. The court held that if a person provides a substance with the specific intent that it be used to kill another, and that substance is later administered by an unconscious agent, the death is a murder for which the original provider is responsible. The unconscious agent, in this case the five-year-old child, is treated in law as a mere instrument in the hands of the defendant. The defendant's original murderous intent continued, and she was the direct cause of the death because she put the poison in a position where it could be administered, and it was.
Analysis:
This case is a foundational decision in criminal law regarding the principles of causation and the doctrine of innocent agency. It establishes that the actus reus (the guilty act) of a crime can be committed through an innocent third party. The court's reasoning effectively states that the actions of an unconscious or innocent agent do not break the chain of causation originating from the defendant's mens rea (guilty mind). This precedent solidifies that a defendant cannot escape liability by using an unwitting intermediary to perform the final physical act of the crime, treating the agent as a mere instrument of the defendant's will.
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