United States v. Hatfield
United States Court of Appeals for the Seventh Circuit
591 F.3d 945 (2010)
Four drug users bought illegal drugs from Rex Hatfield and his partners (defendants) and later died after ingesting drugs, though the buyers likely also used drugs from other sources. The government prosecuted the partners for causing the deaths, and the evidence that the partners rather than other sources supplied the fatal drugs was strong but inconclusive. The trial judge instructed the jury it could convict if the drugs were merely a factor in the deaths and need not be the primary cause, over the defendants' objection. The jury convicted, and the defendants appealed.
Whether a defendant may be convicted of causing a death based on a jury instruction that the defendant's drugs need only have been a factor in the death, without requiring proof that the death would not have occurred but for the defendant's conduct.