Hubbard v. Commonwealth

Brief Fact Summary.

Hubbard (Defendant) resisted being taken to jail. Following the scuffle, the jailor suffered a heart attack and died. Defendant was convicted of voluntary manslaughter for the death, and appealed, arguing that his actions were not the legally proximate cause of the death.

Synopsis of Rule of Law.

An accused is only criminally responsible for a death if death or serious bodily harm was the probable and natural consequence of his actions.

Facts.

Defendant was arrested for public drunkenness and taken before a judge. He was too intoxicated to be immediately tried and was ordered detained. Defendant resisted and the jailor tried to subdue him in a scuffle. Defendant did not strike the jailor and the jailor did not receive any physical injury during the struggle. Defendant finally calmed down and was taken out of the courthouse. As they left, the jailor suffered a fatal heart attack. Defendant was convicted of voluntary manslaughter. Defendant appealed, arguing that his resistance was not the legally proximate cause of the jailor’s heart attack and death.

Issue.

Must death or serious bodily harm be the probable and natural consequences of a defendant’s actions for him to be criminally responsible?

Held.

(Stanley, Comm.) Yes. An accused is only criminally responsible for a death if death or serious bodily harm was the probable and natural consequence of his actions. When a death is caused by a direct blow, injury, or hostile act directed at the decedent, a person can clearly be held responsible. But when the defendant’s action is an indirect, but unlawful one, the act must be one where death or serious bodily injury is the natural or probable consequence for the defendant to be criminally liable. Here, Defendant’s act was too remote to have been the proximate cause of the death. The jailor had a heart condition, which he was aware of, and worked in a job with potential for stress and exertion. Reversed.

Discussion.

When factors other than a defendant’s actions contribute to a death or hasten it, the defendant cannot escape responsibility for his actions. Even non-contact causes, such as fear, fright, or nervous shock, can lead to conviction. However, when there is an intervening cause, that is not the defendant’s fault, and without which the death would not have occurred, the defendant is not criminally responsible for the death.