Commonwealth v. Atencio
Supreme Judicial Court of Massachusetts
189 N.E.2d 323 (1963)
Atencio and Marshall (defendants) drank with the Britch brothers and, after Marshall produced a revolver loaded with a single bullet, all three men took turns pointing the gun at their own heads and pulling the trigger as part of an impromptu game of Russian roulette; when the gun reached Stewart Britch, he spun the cylinder himself, pulled the trigger, and was killed by the round. Atencio and Marshall were convicted of manslaughter and appealed, arguing Stewart's own voluntary act of pulling the trigger broke any causal link to their conduct.
Whether, where there is mutual encouragement in a wanton and reckless joint enterprise, such conduct may be found to be a direct link in the death of another.