State v. Leopold
Connecticut Supreme Court of Errors
147 A. 118 (1929)
Leopold (defendant) hired Weiss to burn down a building to collect insurance on furniture owned by the Waterbury Furniture Company, in which Leopold was a minority shareholder. Another part of the building held an apartment where two boys and their father lived. The resulting fire killed Weiss and both boys. Leopold was indicted for first-degree murder; at trial he asked the judge to instruct the jury that an intervening act by the boys -- specifically, their father stopping them from leaving immediately so they could grab valuables first -- should relieve him of liability, but the court refused. Leopold was convicted and appealed.
Whether, in Connecticut, a defendant may be guilty of murder if death results, not necessarily immediately from the defendant's act, but from the natural sequence of events put into motion by the defendant's wrongful action.