Facts
- In the early morning hours of May 6, 2023, Samuel McCray entered a Detroit gas-station convenience store where Al‑Hassan Walid Aiyash worked as the attendant.
- McCray selected about four dollars’ worth of snacks and beverages and attempted to pay, but his card was declined.
- McCray threatened to kill Aiyash and tried to leave the store with the unpaid items.
- From behind bullet-resistant glass, Aiyash remotely locked the store’s only door, preventing McCray from leaving and trapping McCray inside with three patrons.
- Aiyash did not know McCray was armed.
- For several minutes, Aiyash verbally taunted McCray while the patrons repeatedly pleaded with Aiyash to open the door and let McCray leave; one patron attempted to calm McCray.
- Aiyash eventually released the door lock and opened the door.
- After the door opened, McCray—believing that one of the patrons had insulted him—pulled a gun and shot all three patrons.
- Gregory Kelly was shot multiple times and died; the other two patrons were also shot and survived.
- The prosecution charged Aiyash with involuntary manslaughter, alleging that Aiyash’s conduct (locking the door and escalating the confrontation) caused Kelly’s death.
- The district court bound Aiyash over for trial, and the circuit court affirmed the bindover; Aiyash sought interlocutory review in the Michigan Court of Appeals.
Issues
- Whether Aiyash’s conduct in locking the store’s door and prolonging the confrontation could be a proximate cause of Gregory Kelly’s death for purposes of involuntary manslaughter.
- Whether McCray’s intentional shooting was an intervening, superseding cause because it was not reasonably foreseeable from Aiyash’s conduct.
Decision
- The Michigan Court of Appeals reversed the circuit court order affirming the bindover.
- The court reasoned that, even assuming the prosecution could show factual causation, involuntary manslaughter also requires criminal proximate cause.
- McCray’s intentional act of shooting the patrons was not reasonably foreseeable from Aiyash’s conduct and therefore severed the causal connection needed to hold Aiyash criminally liable for Kelly’s death.
- Because proximate cause was not established on the prosecution’s theory, bindover on involuntary manslaughter was improper.
Legal Principles
- Involuntary manslaughter requires proof that the defendant’s conduct was both a factual cause and a proximate (legal) cause of the victim’s death.
- Criminal proximate cause turns on reasonable foreseeability: the death must be a direct and natural result of the defendant’s conduct in light of the risks the conduct created.
- An intervening act may break the chain of causation when it is independent of the defendant’s conduct and not reasonably foreseeable.
- A third party’s intentional criminal act commonly constitutes a superseding cause unless the prosecution shows that such intentional violence was a reasonably foreseeable result of the defendant’s actions.
- At bindover, the prosecution must present evidence supporting probable cause for each element of the charged offense, including proximate cause.
Conclusion
In People v. Aiyash, the Michigan Court of Appeals held that the prosecution failed to show that the gas-station attendant’s decision to keep the store door locked during a dispute over a small unpaid purchase was a proximate cause of a patron’s death, because the customer’s later decision to pull a gun and shoot bystanders was not reasonably foreseeable and therefore operated as a superseding intervening cause; the court reversed the order affirming bindover on involuntary manslaughter.