People v. Flenon

Flenon (defendant) shot Johnson in the leg, requiring amputation and a blood transfusion; Johnson died five weeks later from serum hepatitis contracted through the necessary transfusion, a common but foreseeable complication given his near-certain exposure through the amount of blood needed, even though the actual death rate from exposure was low. Flenon was convicted of first-degree murder and appealed, arguing the disease was an intervening cause breaking the chain of causation.