People v. Lewis
57 P. 470, 1899 Cal. LEXIS 1034, 124 Cal. 551 (1899)
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Rule of Law:
A defendant who inflicts a mortal wound upon a victim is criminally liable for the resulting death, even if the victim subsequently inflicts a second, independent fatal wound upon themselves, so long as the original wound was a contributing cause at the time of death.
Facts:
- Defendant Lewis and the deceased, Farrell, were brothers-in-law who were not on friendly terms.
- On the morning of the homicide, Farrell visited Lewis's home where an altercation arose.
- Lewis shot Farrell in the abdomen with a rifle, inflicting a wound that medical evidence established was necessarily mortal and would cause death within one hour.
- Farrell was taken inside and put to bed.
- A few minutes later, while only Lewis's young son was present, Farrell procured a knife and cut his own throat.
- The self-inflicted throat wound was also fatal and was expected to cause death within five minutes, thereby accelerating Farrell's death.
Procedural Posture:
- Lewis was tried and convicted of manslaughter in a state trial court.
- The trial court denied Lewis's motion for a new trial.
- Lewis (appellant) appealed the judgment of conviction and the order denying a new trial to the Supreme Court of California.
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Issue:
Does a defendant's act of inflicting a mortal wound constitute the legal cause of death when the victim, still alive but dying from the wound, subsequently inflicts a second, fatal wound that accelerates death?
Opinions:
Majority - Temple, J.
Yes, the defendant's act constitutes the legal cause of death. A defendant is criminally responsible for a death if the wound they inflicted was a contributing cause at the moment of death, even if other independent causes also contributed. The court reasoned that the test for causation is whether the defendant's wound contributed to the fatal event. Here, Farrell was actively dying from the mortal gunshot wound when he cut his throat. The court found that both wounds were concurrently and actively contributing to the loss of life at the moment of death. Therefore, the self-inflicted wound, while accelerating death, was not an independent intervening cause that superseded the gunshot wound as a legal cause of death.
Analysis:
This case solidifies the 'contributing cause' theory of homicide liability in situations with multiple causes of death. It establishes the precedent that a victim's own subsequent fatal act does not sever the chain of causation if the defendant's initial mortal wound is still an operative and contributing cause at the moment of death. This decision narrows the scope of what can be considered a superseding intervening cause, making it more difficult for a defendant who inflicts a mortal wound to escape liability by pointing to a later event that merely hastens the inevitable result of their actions. The ruling reinforces that responsibility attaches when a defendant's felonious act sets in motion a chain of events leading to death, unless that chain is completely broken by a sole, independent cause.
