State v. McFadden
Iowa Supreme Court
320 N.W.2d 608 (1982)
- Written by Craig Conway, LLM
Facts
Michael McFadden (defendant) and Matthew Sulgrove engaged in a drag race. Sulgrove lost control of his car and swerved into a lane of oncoming traffic where his vehicle struck another vehicle, killing him and a girl in the other car. McFadden’s car did not physically contact either of the other cars. McFadden was charged with two counts of involuntary manslaughter. McFadden waived his right to a jury trial and was found guilty on both counts under each of three separate theories, namely that (1) he aided and abetted Sulgrove in committing involuntary manslaughter, (2) he was vicariously responsible for Sulgrove’s commission of involuntary manslaughter by reason of their joint participation in the public offense of drag racing, and (3) that McFadden himself committed involuntary manslaughter by recklessly engaging in a drag race so as to proximately cause the Sulgrove collision. McFadden appealed, arguing that the element of causation was absent.
Rule of Law
Issue
Holding and Reasoning (Allbee, J.)
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