United States v. Pineda-Doval

Adan Pineda-Doval (defendant) smuggled ten undocumented immigrants across the border in an overcrowded, seatbelt-less Suburban. When a Border Patrol officer gave chase, another officer deployed a tire-puncturing spike strip Pineda-Doval had encountered on two prior smuggling runs; he swerved sharply to avoid it, but a tire blew, and the Suburban flipped, ejecting and killing all the passengers. The jury was instructed to convict if Pineda-Doval exposed his passengers to at least one life-threatening condition that caused their deaths, and he was convicted of felony murder under 8 U.S.C. § 1324; he appealed, arguing the instruction should have required proximate cause of death.