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Law School Case Brief

United States v. Hamilton - 182 F. Supp. 548 (D.D.C. 1960)

Rule:

If a person strikes another and inflicts a blow that may not be mortal in and of itself but thereby starts a chain of causation that leads to death, he is guilty of homicide. This is true even if the deceased contributes to his own death or hastens it by failing to take proper treatment.

Facts:

Defendant and the deceased were in a fight when the deceased was knocked down in the course of the fight, and defendant jumped on his face and kicked his face, inflicting wounds of which the deceased later died. The deceased was taken to the hospital for treatment. During the deceased's stay at the hospital, he had a convulsion, and immediately thereafter, he himself, with his own hands, pulled out the tubes that were assisting him to breathe. The cause of death was found to be asphyxiation due to aspiration or inhalation of blood caused by severe injuries to the face. Defendant claimed that the immediate cause of death was the fact that the deceased pulled out the tubes, and that, therefore, he brought about his own death. The district court found defendant guilty of manslaughter.

Issue:

Could defendant be convicted of manslaughter on account of a wound he inflicted even if the deceased contributed to his own death?

Answer:

Yes.

Conclusion:

Even if the act of the deceased in pulling out the tubes was conscious and deliberate, it would not have helped defendant. There was not sufficient evidence to justify a finding that if the tubes had remained the deceased would have lived.

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