State v. Myers
81 A.2d 710, 25 A.L.R. 2d 1171, 7 N.J. 465 (1951)
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Rule of Law:
A defendant is criminally responsible for homicide when their course of assault and threats causes a victim, under a well-grounded apprehension of immediate and severe violence, to take a fatal action in an attempt to escape.
Facts:
- The defendant and his wife had a stormy and violent marriage.
- Five days after his wife left him, the defendant saw her in a tavern with two men, which made him angry.
- He confronted her outside, hit her, and chased her as she fled toward the Jackson Street bridge, repeatedly punching her with his open hand and fists.
- At the bank of the Passaic River, he cornered her, continued the assault, and commanded her to jump into the river.
- After she hesitated, he threatened three times, "if she did not jump in I would push her in."
- The wife then let go of the dock's edge, dropped into the river, and began to struggle and call for help.
- The defendant stood and watched her drown for about a minute without rendering aid or calling for help before running away.
Procedural Posture:
- The defendant was indicted for the murder of his wife.
- Following a trial in a New Jersey court of first instance, a jury convicted the defendant of murder in the first degree.
- The jury recommended a sentence of life imprisonment, which the trial court imposed.
- The defendant appealed his conviction to the Supreme Court of New Jersey.
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Issue:
Is a defendant criminally responsible for homicide when his assaults and threats cause his victim, under a well-grounded apprehension of immediate and severe violence, to jump into a river and drown?
Opinions:
Majority - Wachenfeld, J.
Yes. A defendant is criminally responsible for homicide because his unlawful conduct was the proximate cause of the death. The court reasoned that a person's act is not voluntary if it is compelled by force applied to the body or mind. Citing the rule from Regina v. Pitts, the court stated the victim's apprehension of violence must be immediate and well-grounded, and the fatal step taken must be one a reasonable person might take to escape. Here, the defendant's violent onslaughts and frightening threats reduced his wife to a state of terror, cornering her between her assailant and the river. Her act of jumping into the water was a choice between what she seemingly thought were two evils, directly caused by the defendant's conduct. The defendant's intent to kill was further evidenced by his cruel inaction as he watched her struggle and drown, which 'clearly proves the design he formulated—the riddance of his wife.'
Analysis:
This case solidifies the principle of proximate causation in homicide law, affirming that a defendant can be held liable for murder even if the victim's own act is the immediate cause of death. It establishes that a defendant's terror-inducing conduct, which foreseeably leads a victim to take a fatal step to escape, does not break the chain of causation. The decision is significant for cases involving domestic violence, as it provides a clear legal basis for holding abusers responsible when their victims die while attempting to flee a violent attack.
