Criminal Law Keyed to Johnson
Todd v. State
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- Topic: Identifies the topic of law and where this case fits within your course outline.
- Parties: Identifies the cast of characters involved in the case.
- Procedural Posture & History: Shares the case history with how lower courts have ruled on the matter.
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- Facts: What are the factual circumstances that gave rise to the civil or criminal case? What is the relationship of the Parties that are involved in the case. Review the Facts of this case here:
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 Defendant. 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. Defendant 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. Defendant 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 Defendant did not know of the condition. The trial court denied the motion. Defendant was offered a plea agreement and pled guilty to the manslaughter offense. The agreement reserved Defendant’s right to appeal the denial of his motion to dismiss, which he did.
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