State v. Shabazz

Supreme Court of Connecticut · 1998 · Evidence

246 Conn. 746 (1998)

Updated August 22, 2026

Evidencecausationintervening causemedical negligencesole causehomicidemotion in liminerelevance

Facts

After a fight began at pay telephones on the New Haven green, the defendant repeatedly stabbed the victim while preventing him from escaping and continued stabbing him after he fell to the ground. The victim was taken to Yale-New Haven Hospital, underwent surgery, and died about twelve hours later from stab wounds to the chest and abdomen. Before trial, the defendant sought to introduce expert testimony that grossly negligent hospital treatment caused the victim's death, including claims about anticoagulant use and failure to place him in intensive care. The trial court excluded that evidence and later barred cross-examination of the medical examiner on hospital treatment.

Issue

Whether the trial court properly excluded evidence that gross medical negligence by the hospital caused the victim's death. The appeal also presented whether certain other evidentiary exclusions and the denial of a recusal motion required reversal.

Rule

Where death results from a dangerous wound inflicted by the defendant, negligent or unskilled medical treatment that aggravates the injury ordinarily is no defense. Gross maltreatment by attending physicians constitutes a defense only in the exceptional case in which that maltreatment is the sole cause of the victim's death. For nonconstitutional evidentiary error, the defendant must show harm; the court described that burden as either showing it is more probable than not the ruling affected the result or that the ruling caused substantial prejudice.

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

In Phoenix, Nolan Price stabbed Victor Mendez in the abdomen, lacerating the liver. At trial for murder, Nolan offered a trauma surgeon who would testify that the hospital later delayed internal bleeding checks for hours and that Victor probably would have survived with proper monitoring, but the surgeon also admitted the wound was life-threatening and would have been fatal without treatment.

Should the trial court admit the medical-negligence testimony to negate causation?

Explanation. The majority rule is that when a defendant inflicts a dangerous wound, negligent or even grossly negligent treatment is ordinarily no defense. It matters only in the exceptional case where the maltreatment is the sole cause of death. Here, the expert conceded the stab wound itself was fatal if untreated, so the negligence would at most be a contributing cause, not the sole cause.