People v. Caldwell

Ernest Caldwell and Warren Washington (defendants) were convicted of robbery and the murder of Anthony Belvin. Caldwell, Washington, and Belvin were co-felons in a robbery committed at a fast-food restaurant one night. Police arrived as they were leaving the scene, and a high-speed chase ensued. Caldwell was the driver, reaching speeds up to 70 miles per hour and running through stop signs and red lights, all while leaving the car’s headlights off. Washington was the front passenger and, when the car finally came to a rest surrounded by police cars, pointed a shotgun at the police car directly opposite them. The officer driving that car hit the accelerator, and Washington’s shotgun discharged. No one was shot, but the gun skidded across the street. Caldwell, Washington, and Belvin exited the car and crouched around it. Police thought Caldwell and Belvin had visible handguns, although Caldwell’s was never recovered. Officers shot at the three men, and Belvin died from a bullet wound. The officers’ testimony at trial differed in a few respects, including as to what led them to begin firing, with some testifying that Belvin was waving his gun around and another testifying that he saw Caldwell focus his attention on the officer’s partner while holding a gun and shot to protect his partner. Officers also confirmed that they instructed the men to drop their weapons prior to opening fire. Caldwell and Washington appealed their murder convictions on the grounds that they had not proximately caused Belvin’s death.