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United States v. Pritchard

United States Court of Appeals for the Sixth Circuit

964 F.3d 513 (2020)

Facts

Steve Pritchard (defendant) was an arsonist who repeatedly committed insurance fraud. In June 2011, Pritchard started a fire that led to the death of a firefighter, Charles Sparks. Sparks suffered a fatal heart attack while responding to the fire started by Pritchard. Sparks had a history of heart disease and did not strictly adhere to instructions regarding the use of his prescription medication. Pritchard was charged with arson causing death. At trial, the government (plaintiff) introduced evidence that firefighting strains the heart, which might potentially cause a heart attack. The jury convicted Pritchard of arson causing death. Pritchard was sentenced to 360 months in prison. Pritchard appealed his conviction and sentence, arguing that the proximate-cause element was not satisfied because Sparks’s heart attack was not foreseeable and that the evidence was insufficient to support a conviction.

Rule of Law

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Issue

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Holding and Reasoning (Nalbandian, J.)

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