United States v. Hamilton

Brief Fact Summary.

Hamilton (Defendant) severely beat the victim. While in the hospital, the victim convulsed and pulled tubes out of his throat, dying from asphyxiation. Defendant was then charged with second-degree murder.

Synopsis of Rule of Law.

When an individual inflicts a wound on another that is not fatal, but sets in motion a chain of causation which results in the victim’s death, he is guilty of murder.

Facts.

Defendant severely beat the victim, continuing to attack him even after the victim had fallen to the ground. The victim was hospitalized and had tubes inserted into his throat to keep his airway clear. Three days later, the victim convulsed and pulled the tubes out. He died of asphyxiation and Defendant was charged with second-degree murder. 

Issue.

When an individual inflicts a nonfatal injury on another, but sets in motion a chain of causation which results in the victim’s death, is he guilty of murder?

Held.

(Holtzoff, J.) Yes. When an individual inflicts a wound on another that is not fatal, but sets in motion a chain of causation which results in the victim’s death, he is guilty of murder. Although the victim in this case removed his own breathing tubes and caused his own death, that fact is immaterial. So long as the victim’s death was a natural and probable consequence of Defendant’s criminal conduct, Defendant is responsible. Defendant is guilty of second-degree murder.

Discussion.

Criminal responsibility is clearest when the victim’s reaction to an assault is instinctive, such as when a victim runs into the street and is struck by a car while fleeing the assault. Cases like this one, where the victim’s act is more voluntary than instinctive, are more difficult. Courts have found individuals guilty even in extreme cases, such as when a victim refused an operation that would have saved his life. Although the victim’s decision was unreasonable, it was not abnormal, and the individual who assaulted him was held responsible for his death.