State v. Jenkins
South Carolina Supreme Court
277 S.E.2d 147 (1981)
Relevant factsFree
Robert Jenkins (defendant) stabbed the victim, causing heavy blood loss. At the hospital, doctors ran a routine arteriogram using a dye, and the victim had a rare, fatal allergic reaction to the dye. That reaction was the immediate cause of death, but the victim would have died anyway without treatment. The state (plaintiff) charged Jenkins with murder; the jury was told there had to be a causal link between his stabbing and the death, and it convicted him of murder. Jenkins appealed.
IssueFree
Whether a person who inflicts an injury on another is guilty of homicide if that injury contributes to the victim's death, even though something else was the immediate cause.