State v. Wilson
421 P.3d 742 (2018)
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Rule of Law:
A defendant who initiates a violent criminal act is the proximate cause of a resulting death, even if the fatal blow is delivered by a third party, so long as the third party's action was a foreseeable defensive response to the defendant's conduct and not an extraordinary, superseding event.
Facts:
- Matthew Wilson lived across the hall from an apartment occupied by Dustin Ferguson and Joel Solano.
- At approximately 4 a.m. on April 7, 2013, Wilson ambushed Ferguson and three guests—Michael Lowery, Alexya Mailea, and Christine Kim—in the hallway with a handgun.
- Wilson shot and injured Ferguson, Mailea, and Kim, telling the women he was only 'there for the guys.'
- Wilson then shot his way through the locked front door and entered Ferguson and Solano's apartment.
- Inside, Joel Solano had been awakened by the gunfire and armed himself with his own handgun.
- Michael Lowery, fleeing from Wilson, ran into the dark bedroom where Solano was hiding.
- Solano, mistaking Lowery for Wilson, shot and killed Lowery.
- Wilson attempted to enter Solano's bedroom but was blocked by Lowery's body; he then left the apartment and was arrested.
Procedural Posture:
- The State charged Matthew Wilson in Riley County District Court (trial court) with first-degree murder and other offenses.
- Pursuant to a plea agreement, Wilson pled no contest to first-degree premeditated murder, two counts of attempted murder, and two counts of aggravated battery.
- The district court accepted the plea, found Wilson guilty, and sentenced him to life imprisonment.
- On an initial direct appeal, the Kansas Supreme Court affirmed Wilson's consecutive sentences.
- Wilson then filed a pro se motion in the district court to withdraw his no contest plea, arguing no factual basis existed for the murder charge.
- The district court summarily denied Wilson's motion without an evidentiary hearing.
- Wilson appealed the summary denial of his plea withdrawal motion to the Kansas Supreme Court.
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Issue:
Does a defendant's act of initiating a deadly shooting spree constitute the proximate cause of a victim's death when another individual, acting in self-defense, mistakenly shoots and kills the victim?
Opinions:
Majority - Stegall, J.
Yes. A defendant's attack is the proximate cause of a death when it foreseeably provokes a third party to take defensive action that results in the victim's death. Wilson's violent assault created a chaotic and deadly situation, making it reasonably foreseeable that an occupant like Solano would take defensive action. The court reasoned that criminal liability for a death requires proximate cause, which consists of cause-in-fact ('but-for' causation) and legal causation (foreseeability). While Wilson did not fire the fatal shot, his actions were the cause-in-fact of Lowery's death. The key question is whether Solano's defensive shooting was a superseding cause that broke the chain of legal causation. Citing precedents from cases involving medical negligence, police pursuits, and felony murder, the court held that an intervening act only severs liability if it is an 'extraordinary intervening event' that becomes the 'sole legal cause of death.' Solano's action, spurred by the 'basic human instinct' to resist a sudden show of force and defend oneself and family, was a foreseeable consequence of Wilson's attack, not an extraordinary event. Therefore, Wilson proximately caused Lowery's death.
Analysis:
This decision solidifies the application of proximate cause in homicide cases where a defendant's actions precipitate a fatal response from a third party. It establishes that a foreseeable defensive act, even if mistaken, does not sever the causal chain originating from the defendant's initial criminal conduct. By holding the original aggressor responsible for the predictable consequences of the chaos they create, the ruling makes it more difficult for defendants to evade liability by blaming the immediate actions of others who are reacting to the danger. This precedent reinforces the principle that 'violence begets violence' and holds the instigator accountable for the full scope of the foreseeable harm.
