Letner v. State case brief

Letner v. State case brief summary
299 S.W. 1049 (1927)

CASE SYNOPSIS

Defendant challenged the decision of the Criminal Court of Morgan County (Tennessee), which found him guilty of involuntary manslaughter.

CASE FACTS
The victims drowned after shots were fired at their boat, resulting in it capsizing.

DISCUSSION

• On review, the court affirmed. 
• The court found from a preponderance of the testimony that the shots were fired by defendant. 
• The court determined that the act of defendant, whether he was shooting to kill or only to frighten the victims, was an unlawful one and came within the universal rule that every person was held to contemplate and be responsible for the natural consequences of his own act, but was not criminally responsible for a homicide unless the act was the cause of death. 
• The court found that defendant could not escape the consequences of his wrongful act by relying upon a supervening cause when such cause naturally resulted from his wrongful act. 
• The court determined that by firing the gun defendant caused one of the victims to take to the water, resulting in the overturn of the boat and the drowning of the second victim. 
• The court concluded that the wrongful act of defendant was the primary proximate cause of the victims' death, that the act capsizing of the boat was the natural result of the wrongful act, and defendant was liable for the victims' consequential death.

CONCLUSION
The conviction for involuntary manslaughter was affirmed.


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