State v. McFadden

320 N.W.2d 608 (Iowa 1982)



A state does not need to use the "direct causal connection" standard to find liability. Criminal liability may be found where the defendants actions were found to be the proximate cause of another death.


A drag race between two drivers, McFadden and Sulgrove, which occurred on a Des Moines city street. During the course of the two vehicles' southbound progression, Sulgrove lost control of his automobile and swerved into a lane of oncoming traffic, where he struck a lawfully operated northbound vehicle. The third vehicle contained a 6 year old passenger who was killed in the collision along with Sulgrove. McFadden's automobile did not physically contact either of the two colliding vehicles. He was charged and convicted with two counts of involuntary manslaughter. The case was appealed to the Supreme Court of Iowa.


Was the conviction proper?




The court held that the other driver's voluntary and reckless participation in the drag race did not of itself bar defendant from being convicted of involuntary manslaughter for the other driver's death. The court further determined that the trial court had not erred in applying ordinary proximate cause principles to determine whether the causation element of § 707.5(1) had been met, and in declining to adopt the more stringent "direct causal connection" standard. The court finally concluded that a separate and distinct offense arose from each death caused by defendant's single act.

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