## Facts

- Randy L. Brackett, an Illinois prisoner, was convicted in state court of felony murder arising from the rape and severe beating of an 85-year-old widow, Mrs. Winslow.
- The assault caused serious injuries (including broken bones, extensive bruising, and facial injuries) and was followed by a marked physical and psychological decline during hospitalization.
- After transfer to a nursing home, Mrs. Winslow remained unable to eat normally and required assisted feeding; a nasogastric feeding tube could not be inserted, partly because facial injuries made insertion too painful.
- Approximately ten days after admission to the nursing home, she died when a large quantity of food became lodged in her trachea, causing asphyxiation.
- The Illinois Supreme Court affirmed the conviction on direct review.
- Brackett sought federal habeas relief, arguing the evidence was constitutionally insufficient to prove his conduct legally caused death; the district court denied the petition, and he appealed.

## Issues

1. Whether, under due process standards for evidentiary sufficiency, a rational factfinder could find beyond a reasonable doubt that Brackett’s rape and beating legally caused Mrs. Winslow’s death.
2. Whether the nurse’s feeding (and related medical-care decisions) constituted a superseding cause that severed causation for felony murder.

## Decision

- The court affirmed the denial of the habeas petition.
- Applying the deferential sufficiency standard, the court held that a rational factfinder could conclude Brackett’s assault was both a factual cause of the death and a legal cause because it increased the risk of the fatal choking event.
- The nurse’s feeding, even if negligent, was not a superseding cause because it was a foreseeable response to the victim’s debilitated condition created by the assault.

## Legal Principles

- On federal habeas review of a state conviction, the question is whether any rational trier of fact could have found the challenged element beyond a reasonable doubt when viewing the evidence in the prosecution’s favor.
- Criminal causation requires more than “but-for” linkage; an act must also make the harmful result more likely in the relevant way to qualify as a legal cause.
- A defendant’s conduct need not be the sole cause of death; contributing causes may coexist.
- Medical or caregiving acts responding to injuries typically do not break the causal chain unless they are so abnormal and unforeseeable as to constitute a superseding cause.

## Conclusion

The Seventh Circuit held that the record allowed a rational factfinder to treat Brackett’s assault as a legal cause of the victim’s fatal asphyxiation and rejected the claim that subsequent feeding and medical-care decisions severed causation; habeas relief was therefore unavailable.


Brackett v. Peters, 11 F.3d 78 (7th Cir. 1993)