State v. Govan
744 P.2d 712 (1987)
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Rule of Law:
A defendant's act is the proximate cause of a victim's death, even if death occurs years later from a medical condition that arose as a foreseeable response to the initial injury. An intervening medical condition or the victim's loss of will to live does not sever the chain of causation if it is a foreseeable consequence of the defendant's conduct.
Facts:
- On April 5, 1980, the appellant and Ms. Sharon Keeble were involved in an argument, during which Keeble fired a shot at the appellant.
- Later that day, the two were arguing again, and while Keeble attempted to call the police, the appellant shot her in the neck.
- The gunshot wound caused Keeble to become a quadriplegic, paralyzed from the neck down.
- Due to her quadriplegia, Keeble required constant care and suffered from various health ailments.
- In January 1985, nearly five years after the shooting, Keeble contracted pneumonia and died.
- Medical testimony established that the pneumonia stemmed from the quadriplegia, which was directly caused by the gunshot wound.
Procedural Posture:
- On May 1, 1980, the state charged the appellant with aggravated assault for shooting Ms. Keeble, a charge that was later dismissed without prejudice.
- Following Ms. Keeble's death, the state indicted the appellant on one count of second-degree murder on May 13, 1985.
- At the conclusion of the state's case in the trial court, the appellant moved for a judgment of acquittal, arguing there was insufficient evidence of causation.
- The trial court denied the motion for acquittal.
- On October 18, 1985, a jury convicted the appellant of the lesser-included offense of manslaughter.
- The appellant was sentenced to a six-year term of imprisonment and subsequently appealed his conviction to this intermediate appellate court.
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Issue:
Does a defendant's act of shooting a victim remain the proximate cause of death when the victim dies nearly five years later from pneumonia, a foreseeable medical complication resulting from paralysis caused by the gunshot wound?
Opinions:
Majority - Greer, Judge
Yes, the defendant's act remains the proximate cause of death. An intervening cause that is a foreseeable 'response' to the defendant's initial act, rather than a 'coincidence,' will only break the chain of causation if it is abnormal and unforeseeable. Here, the victim's quadriplegia was a direct result of the gunshot wound, and her subsequent death from pneumonia was a foreseeable medical complication arising from that paralysis. The court rejected the appellant's argument that the victim's alleged 'loss of will to live' constituted a superseding cause, reasoning that such a state is a foreseeable consequence of the extreme physical and mental suffering inflicted by the defendant's actions.
Analysis:
This case solidifies the principle that foreseeability is the cornerstone of proximate cause in criminal homicide cases. It demonstrates that a substantial time delay between the defendant's act and the victim's death does not automatically break the causal chain. The decision broadens the scope of liability by treating subsequent medical complications and even the victim's deteriorating psychological state as foreseeable consequences of the initial violent act. This precedent makes it significantly more difficult for defendants to evade responsibility for a death by pointing to an immediate, but related, cause like disease, when that disease is a natural result of the injury inflicted.
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