Commonwealth v. Rementer
Superior Court of Pennsylvania
598 A.2d 1300 (1991)
Charles Rementer (defendant) repeatedly beat his girlfriend Mary Berry inside and outside a moving cab during a prolonged confrontation, catching and dragging her back twice after she tried to flee, until she escaped a third time and ran into traffic seeking help, where a passing vehicle's frightened driver pushed her away and drove off, crushing her to death. Rementer was convicted of third-degree murder; he appealed, arguing the death was an unforeseeable result of the passing driver's actions rather than his own conduct.
Whether a defendant may be held criminally liable for a victim's death if his conduct was a direct, substantial, and operative cause of the death, without an intervening act breaking the chain of causation.