State v. McFadden

Supreme Court of Iowa · 1982 · Criminal Law

Criminal Lawinvoluntary manslaughterproximate causedrag racingrecklessnessconcurring causefactual causationlegal causation

Facts

Defendant and Sulgrove engaged in a reckless drag race on a Des Moines city street, with evidence that they drove competitively at high speed and repeatedly blocked each other’s passing attempts. After the race continued over successive hills, Sulgrove lost control, crossed into oncoming traffic, and collided with another vehicle, killing himself and six-year-old Faith Ellis. Defendant’s car did not physically contact either of the colliding vehicles, and he argued that causation was lacking and that he had withdrawn before the crash. The State relied on evidence that the race itself was a substantial, concurring cause of the fatal collision.

Issue

Whether a drag racer may be convicted of involuntary manslaughter for deaths resulting from a co-racer’s crash when the defendant’s vehicle did not physically strike the victims, the co-racer voluntarily participated, and the defendant claims he withdrew before impact. Also, whether multiple deaths from a single act of vehicular involuntary manslaughter support separate sentences.

Rule

Under Iowa Code section 707.5(1), involuntary manslaughter requires that the defendant unintentionally cause the death of another by recklessly committing an underlying public offense. In determining causation, Iowa applies ordinary proximate cause principles rather than a stricter "direct causal connection" standard; a victim’s voluntary participation in the reckless conduct does not by itself bar liability, and claimed withdrawal is not an absolute defense but only a factor bearing on proximate cause and possible superseding cause. A separate and distinct offense arises from each death caused by a single act of vehicular involuntary manslaughter.

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One of 10 multiple-choice questions for this case. Pick an answer to see why.

Late at night in Wichita, Nolan Price and Eric Velez begin racing side-by-side on a four-lane city street at extreme speeds. Eric loses control while trying to stay ahead, crosses the center line, and kills a driver in an oncoming car; Nolan's car never touches either vehicle.

If Nolan is charged with involuntary manslaughter based on his own reckless participation in the race, which is the strongest argument for conviction?

Explanation. The majority held that a racer whose car never strikes the victim may still be convicted under a direct-liability theory if his own reckless commission of the underlying public offense was a proximate cause of the death. Ordinary proximate cause principles apply, and concurrent participation in the race can satisfy causation.