State v. Govan
Court of Appeals of Arizona
744 P.2d 712 (1987)
Joe Govan (defendant) shot his girlfriend, Sharon Keeble, in the neck during an argument, paralyzing her from the neck down; the two later reconciled and married. Five years afterward, Keeble contracted pneumonia related to her quadriplegia but delayed seeking treatment for two weeks despite knowing she was ill, and she eventually died from the pneumonia. Govan was indicted for second-degree murder, convicted of manslaughter, and moved for acquittal, arguing Keeble broke the chain of causation by delaying treatment and effectively giving up her will to live.
Whether a defendant may be held criminally liable for a victim's injury or death if his illegal conduct is the proximate cause of that injury or death.