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State v. Lane

Court of Appeals of North Carolina
444 S.E.2d 233 (1994)


Facts

John Lane, Jr. (defendant), and his two cousins, Steve Coor and Rodney Coor, left Lane’s home and walked to a nearby gas station to buy beer. On their return walk home, the three men encountered Gregory Linton, who was heavily intoxicated, walking along a busy highway. After a brief altercation, Lane swung at Linton’s head. Linton fell down on the cement near the road. The three men returned to Lane’s house. Subsequently, police officers discovered Linton lying in the road. Linton was examined for injuries and then taken into custody for public intoxication. The following day, police officers transported an unconscious Linton from the county jail to the hospital. Linton died two hours later. An autopsy revealed no external injuries, but Linton had extensive internal injuries, including a subdural hematoma, a swollen brain, and bruises. The State of North Carolina (plaintiff) charged Lane with involuntary manslaughter. At trial, the prosecution’s theory was that Linton hit his head on the pavement after Lane punched him. Consequently, the prosecution claimed Lane’s actions directly and proximately caused Linton’s death. The medical examiner agreed and testified that Linton died from blunt-force trauma to his head. At the close of the evidence, Lane moved to dismiss the charge, claiming the prosecution failed to prove that Lane caused Linton’s death. The trial court denied Lane’s motion. Lane was convicted, and he appealed.

Rule of Law

Issue

Holding and Reasoning (Arnold, C.J.)

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