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State v. Garcia

Iowa Supreme Court

616 N.W.2d 594 (2000)

Facts

Alejandro Garcia (defendant) shot Daniel Hernandez Gonzalez four times. One of the bullets perforated Gonzalez’s lungs. After receiving surgery, Gonzalez developed Adult Respiratory Disease Syndrome, which required him to be placed on a ventilator. During Gonzalez’s hospitalization, a hospital employee decided to change the tube connecting Gonzalez to the ventilator. Upon removal of the tube, swelling in Gonzalez’s neck caused his airway to close, and he asphyxiated. Garcia was charged with first-degree murder. Garcia sought to prove that grossly negligent medical treatment was an intervening and superseding cause of Gonzalez’s death, such that Garcia was not liable for murder. Prior to trial, the prosecution moved to exclude evidence regarding this defense. The trial court granted the motion, ruling that the medical treatment could not be a superseding cause of death because the medical treatment was not the sole proximate cause of death—both the shooting and the medical treatment were found to be proximate causes of Gonzalez’s death. Garcia was tried for and convicted of first-degree murder. The court of appeals reversed on the ground that it was error to exclude evidence as to Garcia’s defense. The state (plaintiff) petitioned the Iowa Supreme Court for review.

Rule of Law

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Issue

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Holding and Reasoning (Larson, J.)

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A "yes" or "no" answer to the question framed in the issue section;
A summary of the majority or plurality opinion, using the CREAC method; and
The procedural disposition (e.g., reversed and remanded, affirmed, etc.).

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