Sunday, November 17, 2013

Hubbard v. Commonwealth case brief

Hubbard v. Commonwealth case brief summary
202 S.W. 2d 634 (1947)

CASE SYNOPSIS
Defendant challenged a judgment of the Jackson Circuit Court (Kentucky), which adjudged him guilty of killing a jailer and sentenced him to two years' imprisonment on a charge of voluntary manslaughter.

CASE FACTS
Defendant was arrested for being drunk in a public place and was taken before a judge. Being too drunk to be tried, he was ordered to go to jail but refused to go peaceably. Although defendant never struck the jailer at all, and the jailer received no physical injury, the jailer died shortly thereafter. Defendant was convicted of voluntary manslaughter.

DISCUSSION
  • The court stated that defendant could be guilty of no higher degree of homicide than involuntary manslaughter because the jailer's death was charged to have resulted from defendant's commission of a misdemeanor not of a character to endanger life. 
  • To warrant a conviction for homicide, the act of the accused had to be the proximate cause of death. 
  • If there was an intervening cause for which the accused was not responsible and but for which death would not have occurred, the accused was blameless. 
  • There was no criminal liability unless death or serious bodily harm was the probable and natural consequence of an indirect, unlawful act of the accused.
  • Defendant's misdemeanor had to be regarded as too remote a cause. 
  • The failure of the jailer's diseased heart was the cause of his death; the trial court should have directed an acquittal.

CONCLUSION
The court reversed.

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