McFadden and Sulgrove were
illegally drag racing. They took off down the road driving recklessly. Sulgrove lost control, swerved into oncoming
traffic and ran head-on into another car, killing a young girl, as well as
himself.
McFadden won the race.
McFadden was arrested and
charged with two counts of involuntary manslaughter.
McFadden argued that he
didn't crash into anyone. So regardless of his recklessness he was not the cause of the crash (aka a lack
of causation).
The Trial Court convicted
McFadden of involuntary manslaughter.
He appealed.
The Trial Court found that:
McFadden aided and abetted
Sulgrove's commission of inolvuntary manslaughter.
McFadden was vicariously
responsible for Sulgrove's actions due to their joint participation in a
criminal offense.
McFadden was directly
culpable because he recklessly
engaged in drag racing so was to proximately cause Sulgrove's crash.
The Iowa Supreme Court upheld
the conviction.
The Iowa Supreme Court found
that the first two Trial Court theories (aiding and abetting, vicarious
liability) were enough to convict McFadden foe the girl's death, but not
for Sulgrove's death.
Involuntary manslaughter requires that the perpetrator cause the death
of "another person." Sulgrove could be guilty of killing the
girl, but he obviously could not be convicted of killing himself.
So McFadden could not be
convicted of helping Sulgrove kill himself, since Sulgrove didn't
commit that crime.
However, the Court found
that the third Trial Court theory (proximate cause) was enough to convict
McFadden for Sulgrove's death.
McFadden argued that
Sulgrove was a willing participant, but the Court found that didn't
absolve McFadden of his guilt. His participation in the race was a contributing
and substantial factor in Sulgrove's death.
McFadden argued that the
standard for criminal culpability should be direct causal connection, not just proximate cause, which should only be used for civil (tort)
liability. However the Court felt that proximate cause was the correct standard.
Conversely, the court in Commonwealth
v. Root (170 A.2d 310 (1961))
found that there must be a direct causal connection,
which is a higher standard.
