United States v. Hamilton
United States District Court for the District of Columbia
182 F. Supp. 548 (1960)
Hamilton (defendant) beat another man outside a pool hall, knocking him down, jumping on his face, and kicking him in the head. The victim, bleeding and in shock, was hospitalized with breathing tubes inserted into his nose and trachea; after a violent episode led hospital staff to briefly handcuff him and then remove the cuffs once he calmed down, the victim suffered a convulsion the next morning, pulled out his own tubes, and died shortly after from asphyxiation caused by inhaled blood, according to two expert witnesses. Hamilton was tried for homicide before a judge without a jury and argued he could not be convicted because the victim caused his own death by removing the tubes.
Whether a defendant can be convicted of homicide when he inflicts an injury that is not itself fatal but triggers a chain of causal events leading to death.