Nelson James King (defendant) and Mark Lee Bailey were flying a small airplane carrying over 500 pounds of marijuana to an airfield in Virginia. The marijuana belonged to the aircraft’s owner, who ran a drug-smuggling operation. During the flight, King and Bailey encountered heavy cloud cover and became lost. While King examined navigation maps to determine the plane’s location, Bailey piloted the aircraft. The plane crashed into a mountain, injuring King and killing Bailey. King was charged with felony homicide based on Bailey’s death and the possession of marijuana with intent to distribute. After a trial, King was convicted of second-degree murder. King appealed, arguing that there was no direct link between the marijuana possession and Bailey’s accidental death.