Lewis v. State
Alabama Court of Criminal Appeals
474 So.2d 766 (1985)
Alvin Lewis (defendant) and fifteen-year-old Damon Sanders played Russian Roulette with a revolver, though it was unclear whether the gun was actually loaded at the time; Lewis then put the gun away and left. Sometime later, Sanders was seen alone holding the gun and spinning its chamber, and a gunshot followed: Sanders had shot himself in the head. Lewis was indicted for murder; the trial court granted a judgment of acquittal on murder and manslaughter, but the jury convicted him of criminally negligent homicide, and he appealed.
Whether, in a criminally negligent homicide prosecution, the victim's free will is an intervening cause that breaks the chain of causation and relieves the defendant of criminal culpability.