State v. McFadden
320 N.E.2d 608 (1982)
- McFadden and Sulgrove were illegally drag racing. They took off the road driving recklessly. Sulgrove lost control, swerved into oncoming traffic and ran head-on into another car, killing a young girl, as well as himself.
- McFadden won the race.
- McFadden was arrested and charged with two counts of involuntary manslaughter.
- McFadden argued that he didn’t crash into anyone. So regardless of his recklessness he was not the cause of the crash (aka a lack of causation).
- The Trial Court convicted McFadden of involuntary manslaughter. He appealed.
- The Trial Court found that:
- McFadden aided and abetted Sulgrove’s commission of inolvuntary manslaughter.
- McFadden was vicariously responsible for Sulgrove’s actions due to their joint participation in a criminal offense.
- McFadden was directly culpable because he recklessly engaged in drag racing so was to proximately cause Sulgrove’s crash.
- The Iowa Supreme Court upheld the conviction.
- The Iowa Supreme Court found that the first two Trial Court theories (aiding and abetting, vicarious liability) were enough to convict McFadden foe the girl’s death, but not for Sulgrove’s death.
- Involuntary manslaughter requires that the perpetrator cause the death of “another person.” Sulgrove could guilty of killing the girl, but he obviously could not be convicted of killing himself
- So McFadden could not be convicted of helping Sulgrove kill himself, since Sulgrove didn’t commit that crime.
- However, the Court found that the third Trial Court theory (proximate cause) was enough to convict McFadden for Sulgrove’s death.
- McFadden argued that Sulgrove was a willing participant, but the Court found that didn’t absolve McFadden of his guilt. His participation in the race was a contributing and substantial factor in Sulgrove’s death.
- McFadden argued that the standard for criminal culpability should be direct causal connection, not just proximate cause, which should only be used for civil (tort) liability. However the Court felt that proximate cause was the correct standard.
- Conversely, the court in Commonwealth v. Root (170 A.2d 310 (1961)) found that there must be a direct causal connection, which is a higher standard.