Sunday, November 17, 2013

People v. Lewis case brief

People v. Lewis case brief summary
57 P. 470 (1899)

Defendant appealed a Superior Court of Shasta County (California) conviction of manslaughter and the court's refusal of a new trial.

Defendant appealed a conviction of manslaughter and the court's refusal of his motion for a new trial. In defendant's trial, the prosecution submitted ample evidence that defendant shot the victim and, on the testimony of a nine-year boy, that the victim, feeling he was going to die, inflicted a knife wound which contributed to, if not caused, his death. Defendant argued that to constitute manslaughter he must have killed someone, and if though mortally wounded by defendant, victim actually died from an independent cause, defendant could at most be guilty of felonious attempt.


  • The court disagreed and held the test was whether, when the death occurred, the wound inflicted by the defendant did contribute to the event. 
  • The court held even though self-infliction of a knife wound was an independent cause contributing to victim's death, the causal relation between shooting the victim and the victim's death were properly established.

Defendant's conviction of manslaughter and denial of a new trial were affirmed. Contrary to defendant's arguments that if victim actually died from self-inflicted wound, defendant could only be guilty of felonious attempt for shooting him, the court held defendant guilty of manslaughter because the gunshot wound contributed to victim's death.

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