People v. Jennings
Supreme Court of California
237 P.3d 474 (2010)
After years of Martin Jennings (defendant) and his wife physically abusing and deliberately starving their young son Arthur, leaving him severely emaciated, Jennings struck Arthur in the head with a fireplace shovel shortly before Arthur died within the hour; the forensic pathologist testified Arthur's death resulted from a combination of drugs (including a Unisom dose independently lethal given his frail condition), his physical injuries, and malnutrition, and that death was likely imminent from his overall condition regardless of the drugs. Jennings was convicted, and he appealed, arguing insufficient evidence his physical abuse was a but-for cause of death given the independently lethal drug dose.
Whether a defendant may be held criminally liable for a death resulting from multiple concurrent causes when his own conduct was a substantial contributing factor, even though another independent cause, standing alone, would also have been sufficient to cause the death.