People v. Roberts
Supreme Court of California
826 P.2d 274 (Cal. 1992)
Relevant factsFree
Roberts (defendant), a prisoner, stabbed fellow inmate Charles Gardner; before dying, Gardner picked up the knife, chased Roberts, and in the ensuing struggle stabbed and killed prison guard Albert Patch. The jury was instructed that it was immaterial whether Roberts could have reasonably foreseen Patch's death, and it convicted Roberts of murdering both Gardner and Patch. Roberts appealed the Patch conviction, arguing the instruction improperly removed foreseeability from the jury's consideration.
IssueFree
Whether a defendant may be held liable for the death of a third party caused by the reaction of the defendant's intended victim.