Commonwealth v. Rhoades

Brief Fact Summary.

The judge instructed the jury to find Rhoades (Defendant) guilty of second-degree murder if the victim died “as a result” of Defendant’s actions, or if Defendant’s actions “in any way contributed to hasten, or was part of the proximate cause of the death.” The jury convicted and Defendant appealed.

Synopsis of Rule of Law.

In order to be criminally responsible for a death, the defendant’s actions must be the proximate cause of the death.

Facts.

Defendant set fire to a building. The fire department responded and searched the building for trapped victims. One of the firefighters, Captain Trainor, collapsed on the roof of the building and died. The medical examiner found that he died of a coronary thrombosis, caused by the combination of cold weather, stress, and smoke inhalation. At Defendant’s trial for second-degree murder, the judge instructed the jury that Defendant was guilty if Captain Trainor died “as a result” of Defendant’s actions, or if Defendant’s actions “in any way contributed to hasten, or was part of the proximate cause of the death.” Defendant was convicted and appealed, citing error in the instructions.

Issue.

Must a defendant’s actions be the proximate cause of a death in order to be criminally responsible for the death?

Held.

Yes. In order to be criminally responsible for a death, the defendant’s actions must be the proximate cause of the death. Proximate cause is defined as a cause which, in the natural and continuous sequence, produced the death, and without which the death would not have occurred. Here, the judge’s instructions to the jury allowed Defendant to be convicted for any action that was a link in the chain of events leading to the death, even if that link was remote. The instructions failed to specify that Defendant’s actions needed to be the proximate cause of the death.

Discussion.

Yes. In order to be criminally responsible for a death, the defendant’s actions must be the proximate cause of the death. Proximate cause is defined as a cause which, in the natural and continuous sequence, produced the death, and without which the death would not have occurred. Here, the judge’s instructions to the jury allowed Defendant to be convicted for any action that was a link in the chain of events leading to the death, even if that link was remote. The instructions failed to specify that Defendant’s actions needed to be the proximate cause of the death.