Henderson v. Kibbe

Kibbe (defendant) and a co-defendant robbed an intoxicated victim, Stafford, then abandoned him on a dark road in the snow without a coat, shoes, or glasses. A speeding truck driver-traveling 10 mph over the limit, who saw the victim but did not swerve or stop-struck and killed him. At trial the jury was instructed on recklessness without an explanation of the causation element, and Kibbe argued this was error.

Whether the definition of recklessness includes a requirement of causation.