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State v. Lane - 115 N.C. App. 25, 444 S.E.2d 233 (1994)

Rule:

There can be more than one proximate cause, but criminal responsibility arises as long as the act complained of caused or directly contributed to the crime.

Facts:

Defendant punched the drunk victim, resulting to the latter falling on the cement. The victim was attended to by rescue personnel, who subsequently left upon determination that there was no sign of injury and that the victim was only intoxicated. The victim was thereafter taken into custody and placed in a jail for public drunkenness. Subsequently, the victim died. The autopsy revealed no external injuries, but did reveal a swollen brain, and brain contusions or bruises, among many others. Moreover, according to the medical examiner’s opinion, the victim died as a result of blunt force injury to the head. Defendant was indicted and tried for involuntary manslaughter. The jury returned a verdict of guilty. On appeal, defendant asserted that the State failed to show that the punch was the actual and legal cause of the victim’s death.

Issue:

Did the State fail to show that defendant’s punch was the actual and legal cause of the victim’s death, thereby warranting the reversal of defendant’s conviction?

Answer:

No.

Conclusion:

The Court affirmed the trial court, noting that the State's theory at the time of defendant's motion to dismiss was not limited to whether the victim's head struck the ground after being punched by defendant, and that medical testimony indicated the victim's swollen brain could have been caused by a punch or striking an object. According to the Court, proximate cause was not negated by subsequent negligent medical treatment or the victim's preexisting condition making him unable to withstand an assault. The Court averred that there could be more than one proximate cause, but criminal responsibility would arise as long as the act complained of caused or directly contributed to the crime.

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