State v. Sauter

While intoxicated and arguing with Matt Charles Lines, Richard Robert Sauter (defendant) repeatedly stabbed him; emergency-room surgeons repaired multiple lacerations and stab wounds but failed to repair a one-inch cut, and Lines subsequently lost a substantial amount of blood and died. Sauter was convicted of manslaughter and appealed, arguing that the surgeon's failure to repair the missed wound, not his own stabbing, was the actual cause of death, meaning he could be guilty of assault at most.