Commonwealth v. Atencio 345 Mass. 627, 189 N.E.2d 323 (1963) Atencio, Britch and two other guys were playing Russian Roulette. Several of them took a turn, then Britch pointed the gun to his head and killed himself. Atencio and the other guys were arrested and charged with involuntary manslaughter. The Trial Court convicted the three of involuntary manslaughter. They appealed. The three argued that each person's turn was independent, and Britch's intervening actions meant that they was no direct causal connection between their participation in the game and Britch's death. The Massachusetts Supreme Court upheld the convictions. The Massachusetts Supreme Court found that the defendants were involved in a joint enterprise with Britch and so they were acting recklessly by helping Britch participate in a game that caused his death. The Court distinguished similar cases that resulted in deaths from drag racing by saying that in drag racing, the skill of the racers is a factor, while in Russian Roulette, there is no skill involved. See Model Penal Code §2.03.