Todd v. State
Court of Appeal of Florida for the Fifth District
594 So.2d 802 (1992)
After Todd (defendant) stole $110 from a church collection plate, witness Voegltin, who suffered from an existing heart condition unknown to Todd, chased Todd's car and experienced fatal cardiac dysrhythmia, crashing into a tree and dying of cardiac arrest; Todd was charged with manslaughter under the misdemeanor-manslaughter rule, arguing his theft caused Voegltin's chase and resulting death, and moved to dismiss, arguing his minor theft couldn't be considered the legal cause of an unforeseen heart attack. The trial court denied the motion, Todd pled guilty while reserving his right to appeal that denial, and he appealed.
Whether, in order for a conviction based on the misdemeanor-manslaughter rule to stand, there must be a direct, causal connection between the underlying misdemeanor and the death that follows.