State v. Lane
Court of Appeals of North Carolina
444 S.E.2d 233 (1994)
John Lane, Jr. (defendant) and his two cousins encountered a heavily intoxicated Gregory Linton walking along a highway on their way home from buying beer. After a brief altercation, Lane swung at Linton's head, and Linton fell to the pavement; the group then went home. Police later found Linton lying in the road and took him into custody for public intoxication; the next day, still unconscious, he was rushed to the hospital and died two hours later. An autopsy found no external injuries but extensive internal injuries, including a subdural hematoma and swollen brain. The State of North Carolina (plaintiff) charged Lane with involuntary manslaughter, theorizing Linton hit his head on the pavement after Lane's punch; the medical examiner agreed that blunt-force trauma to the head caused death. Lane's motion to dismiss for insufficient evidence of causation was denied, and he was convicted and appealed.
Whether involuntary manslaughter requires evidence beyond a reasonable doubt that the defendant's action was both the actual cause and the legal cause of the victim's death.