Todd v. State
594 So.2d 802 (1992)
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Rule of Law:
For a conviction of unlawful act manslaughter, the defendant's unlawful act must be the legal cause of the victim's death, which requires that the death be a direct and foreseeable consequence of the act. A non-violent misdemeanor that does not create a direct risk of physical harm cannot serve as the legal cause for a death that occurs as an indirect result of that misdemeanor.
Facts:
- On March 18, 1990, James Walter Todd entered the Lighthouse Church and stole $110 from the collection plate.
- Several members of the congregation, including Richard Voegltin, witnessed the theft.
- Voegltin, who had a preexisting heart condition, began pursuing Todd in his car.
- During the car pursuit, Voegltin experienced cardiac dysrhythmia.
- Voegltin lost control of his vehicle, collided with a tree at a low speed, and died of cardiac arrest.
- Todd had no knowledge of Voegltin's preexisting medical condition.
Procedural Posture:
- The State of Florida charged James Walter Todd with manslaughter in the trial court.
- Todd filed a motion to dismiss the charge, which the trial court denied.
- Todd entered a guilty plea but reserved the right to appeal the trial court's denial of his motion to dismiss.
- Todd, as appellant, appealed the trial court's ruling to the District Court of Appeal of Florida, Fifth District, with the State of Florida as appellee.
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Issue:
Does the commission of a non-violent misdemeanor, such as petty theft, establish the required legal causation for a manslaughter conviction when a witness with a preexisting heart condition dies of a heart attack while pursuing the perpetrator?
Opinions:
Majority - Griffin, J.
No. The commission of a non-violent misdemeanor like petty theft does not establish the required legal causation for a manslaughter conviction under these circumstances. For criminal liability for homicide to attach, there must be a closer and more direct causal relationship between the unlawful act and the death than is required for tort liability. The defendant's act must not only be a cause-in-fact but also the legal cause of death, meaning the death must be a direct and foreseeable result of the act. Here, the petty theft, a minor property offense, did not encompass the kind of direct, foreseeable risk of physical harm that would support a manslaughter conviction. The death resulted from the pursuit, which was an indirect and unforeseeable consequence of the underlying non-violent crime.
Analysis:
This decision significantly clarifies the causation requirement for unlawful act manslaughter in Florida, moving away from a strict application of the misdemeanor-manslaughter rule. It establishes that foreseeability is the critical element of legal causation, requiring that the underlying criminal act itself be inherently dangerous or create a direct risk of physical harm. The ruling prevents the imposition of homicide liability for remote and attenuated consequences of minor, non-violent offenses. This precedent will likely make it more difficult for prosecutors to secure manslaughter convictions where a death results from an unforeseeable chain of events triggered by a non-violent crime.
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