State v. Jones
598 So. 2d 511, 1992 WL 81924 (1992)
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Rule of Law:
In a homicide prosecution, a defendant's act is the legal cause of the victim's death if the act was a substantial factor in bringing about the death or was a clearly contributing cause, even if it was not the sole cause and subsequent medical care may have been inadequate.
Facts:
- On November 6, 1989, Arthur Edward Jones, Jr. and Elzie Wellington were both patrons at Mae's Cafe in Baton Rouge.
- Without any apparent prior argument that evening, Jones struck Wellington a single blow, causing Wellington to fall to the concrete floor and become unconscious.
- While Wellington was unconscious on the floor, Jones approached and kicked or stomped him one or more times.
- Jones's friend had to physically restrain him and escort him from the bar.
- Wellington regained consciousness after 5-10 minutes, was able to speak and walk, and got into an ambulance himself.
- Wellington was transferred from a local hospital to one in New Orleans because the first lacked a neurosurgeon on staff.
- On November 8, 1989, two days after the attack, Wellington died from a subdural hematoma resulting from blunt trauma to the head.
- Jones testified that Wellington had threatened him with a gun, but four state witnesses testified that Jones was the aggressor and they saw no weapons.
Procedural Posture:
- Arthur E. Jones, Jr. was charged by a grand jury indictment with second-degree murder.
- Jones pled not guilty and was tried by a jury in the trial court.
- The jury returned a guilty verdict for the responsive offense of manslaughter.
- The trial court sentenced Jones to twelve years at hard labor.
- Jones (as defendant-appellant) appealed his conviction to the Court of Appeal of Louisiana, First Circuit, against the State of Louisiana (plaintiff-appellee).
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Issue:
Does a defendant's act constitute the legal cause of a victim's death in a homicide prosecution if it is a substantial factor in bringing about the death, even if it is not the sole cause and subsequent medical care may have been inadequate?
Opinions:
Majority - Gonzales, J.
Yes. A defendant's act constitutes the legal cause of a victim's death if the conduct was a substantial factor in bringing about the death. In a homicide prosecution, it is not essential that the defendant's act be the sole cause of death. It is sufficient if the act hastened the termination of life or contributed directly or indirectly to the victim's death in a degree sufficient to be a clearly contributing cause. Here, the coroner confirmed the victim died from a subdural hematoma caused by blunt trauma to the head. The defendant's conduct of punching and stomping the victim was a substantial factor and a clearly contributing cause of this fatal injury, thus establishing legal causation. Any argument about the adequacy of subsequent medical care does not break this chain of causation. Furthermore, the jury was entitled to reject the defendant's self-defense claim by crediting the testimony of state witnesses who identified the defendant as the aggressor, which negates the right to claim self-defense.
Analysis:
This case reaffirms the well-established principle of legal causation in criminal law, specifically that a defendant's act need not be the sole cause of death to sustain a homicide conviction. The court's application of the 'substantial factor' test solidifies that intervening causes, such as potentially negligent medical treatment, will not absolve a defendant of liability unless the intervening cause is the sole cause of death. This decision provides a clear example for future cases where a victim's death occurs sometime after the initial injury and involves subsequent medical intervention, reinforcing that the defendant 'takes his victim as he finds him.' It also highlights the deference appellate courts give to a jury's credibility determinations regarding factual disputes, such as a claim of self-defense.
