State v. Matthews - 450 So. 2d 644 (La. 1984)

Rule:

In a prosecution for murder, the criminal agency of defendant as the cause of the victim's death must be established beyond a reasonable doubt. It is not essential that the act of the defendant should have been the sole cause of the death; if it hastened the termination of life, or contributed, mediately or immediately, to the death, in a degree sufficient to be a clearly contributing cause, that is sufficient.

Facts:

The evidence showed that defendant and his stepson determined to stop the victim from constantly yelling and arguing with them and their family. They drove the victim to a secluded spot then beat her. While she was unconscious, defendant dropped his knee into the middle of her back and smashed her face repeatedly against the concrete. They then left her on a slope beside the highway above a canal. She was discovered in the canal the next night. The cause of death was drowning. Defendant was indicted and convicted for second-degree murder. He was sentenced to life imprisonment at hard labor without benefit of parole, probation, or suspension of sentence. Defendant appealed, arguing that the victim died from drowning rather than from injuries sustained in the beating.

Issue:

Was the defendant’s conviction for second-degree murder proper under the circumstances? 

Answer:

Yes.

Conclusion:

Affirming, the court held that the legal cause of the victim's death was the beating inflicted on her by defendant. He battered her into unconsciousness and then left her body in an isolated spot at night on the slope directly above the canal. While the immediate cause of death was drowning, these acts of defendant were a clearly contributing cause even if the victim rolled, crawled, or stumbled into the water. Viewing the evidence in the light most favorable to the prosecution, a rational trier of fact could have found that the State proved beyond a reasonable doubt the essential elements of second-degree murder. His accomplice's uncorroborated testimony was sufficient to support the conviction.