Todd v. State

594 So.2d 802 (1992)

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Todd v. State

Florida District Court of Appeal
594 So.2d 802 (1992)

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Facts

Todd (defendant) stole $110 from the collection plate of a church. Richard Voegltin, a church member who witnessed the crime, got into his car and drove after Todd. During the chase, Voegltin, who suffered from a heart condition, veered off the road after experiencing cardiac dysrythmia. Voegltin crashed into a tree and died of cardiac arrest. Todd was charged with manslaughter, on the theory that he caused Voegltin’s death by committing the misdemeanor theft, which resulted in Voegltin’s giving chase to retrieve the money. The theory is an embodiment of the misdemeanor-manslaughter rule, which states that an unintended homicide, occurring during the perpetration of a misdemeanor, constitutes involuntary manslaughter. Todd filed a motion to dismiss, contending that his actions cannot be considered the cause of Voegltin’s death, because Voegltin was predisposed to have a heart attack due to his existing condition, and Todd did not know of the condition. The trial court denied the motion. Todd was offered a plea agreement and pled guilty to the manslaughter offense. The agreement reserved Todd’s right to appeal the denial of his motion to dismiss, which he did.

Rule of Law

Issue

Holding and Reasoning (Griffin, J.)

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