Green v. State
Supreme Court of Georgia
470 S.E.2d 884 (1996)
During an argument, Bernard Green (defendant) stabbed his wife Cynthia Grant in the back after she and her child had physically confronted him; a week later, after being medically approved to leave the hospital, Grant suddenly died from a stress ulcer, with conflicting expert testimony at trial about whether the stabbing (through resulting stress and the painkiller Toradol she was given because of it) or the ulcer alone caused her death. Green was convicted of felony murder based on jury instructions allowing conviction if the stab wound directly and materially contributed to a secondary or consequential cause of death, absent an independent intervening cause, and he appealed.
Whether a defendant may be convicted of felony murder where the victim's injury directly and materially contributed to a secondary or consequential cause of death, rather than being the immediate medical cause of death itself.