## Facts

- Early on June 17, 1993, the victim opened her front door and an outer security door to take out the garbage at her home.
- Robert L. Echols was walking past the house after being up all night using drugs.
- Echols saw the victim’s purse inside the home, entered through the open doorway, and grabbed the purse.
- After realizing her purse had been taken, the victim went outside to scream for help and look for Echols.
- While doing so, the victim fell and fractured her hip.
- The victim was hospitalized for several days, underwent weeks of rehabilitation, and testified she experienced significant pain.
- The State of Tennessee charged Echols with aggravated robbery, which (as charged) required proof that the robbery resulted in “serious bodily injury.”
- A jury convicted Echols of aggravated robbery. He appealed, arguing the proof was insufficient because his conduct did not legally cause the victim’s serious bodily injury.

## Issues

1. Whether the evidence was sufficient to prove aggravated robbery where the victim’s serious bodily injury occurred when she fell outside while reacting to the purse-snatching—specifically, whether Echols’s conduct was the proximate (legal) cause of the injury.

## Decision

- The Tennessee Court of Criminal Appeals affirmed Echols’s aggravated robbery conviction.
- The court held that the proof permitted a rational jury to find both causation in fact and proximate causation between Echols’s theft and the victim’s fractured hip.
- The court concluded the victim’s injury was a natural and probable consequence of Echols’s conduct, and the victim’s reaction did not break the chain of legal causation.
- The judgment of the trial court was affirmed (permission to appeal was later denied).

## Legal Principles

- For an offense that requires a particular result, the State must show a causal relationship between the defendant’s conduct and the result.
- Criminal causation includes both: (1) cause in fact (“but for” causation) and (2) proximate (legal) cause.
- A defendant may be held responsible for the natural and probable consequences of his conduct; a victim’s foreseeable reactions to a crime generally do not relieve the defendant of liability.
- On appellate review for sufficiency of the evidence, the question is whether, viewing the evidence in the light most favorable to the State, any rational trier of fact could have found the essential elements beyond a reasonable doubt.
- Serious bodily injury may be shown by proof of significant injury and recovery, including a fracture requiring hospitalization, rehabilitation, and substantial pain.

## Conclusion

State v. Echols held that the evidence supported an aggravated robbery conviction because the victim’s fractured hip, sustained when she ran outside to seek help and look for the thief after he stole her purse, could reasonably be found to be both factually and legally caused by the defendant’s conduct as a natural and probable consequence of the robbery.


State v. Echols, 919 S.W.2d 634 (1995)