People v. Cox

During a dispute, Cox (defendant) punched Spann once in the head, knocking him unconscious; Spann seemed to recover enough to walk back to his room and declined help before going to sleep, but died later that night from a fractured skull. Cox was convicted of involuntary manslaughter under the misdemeanor-manslaughter doctrine, with the jury instructed that the underlying battery was categorically dangerous requiring no further proof of the circumstances, and the court of appeal affirmed before the state supreme court granted review.