People v. Lewis
Supreme Court of California, Department Two
57 P. 470 (1899)
Relevant factsFree
After Lewis shot Farrell in the abdomen inflicting a mortal wound that experts testified would have caused death within about an hour, Farrell instead cut his own throat and died almost instantly from that wound; Lewis argued the throat-cutting was an independent intervening act precluding his manslaughter liability, and requested a jury instruction requiring acquittal if it was impossible to tell which wound caused death.
IssueFree
Whether, in California, two separate individuals may be guilty of homicide if they commit two independent acts which, combined, cause the death of another person.