## Facts

- Alejandro Garcia shot Daniel Hernandez Gonzalez four times, including a bullet that perforated Gonzalez’s lungs.
- Gonzalez survived initial treatment and underwent surgery, later developing adult respiratory distress syndrome and requiring mechanical ventilation.
- While Gonzalez was on a ventilator, a hospital employee removed and attempted to change the tube; swelling in Gonzalez’s neck closed his airway, and he asphyxiated.
- Garcia asserted the hospital’s conduct constituted grossly negligent treatment that intervened and superseded his shooting as the cause of death.
- The State obtained a pretrial ruling excluding evidence and argument supporting the intervening-medical-malpractice theory on the ground that the shooting and treatment were both proximate causes as a matter of law.
- A jury convicted Garcia of first-degree murder; the court of appeals reversed, and the Iowa Supreme Court granted further review.

## Issues

1. When, if ever, does intervening medical negligence sever the causal chain in a homicide prosecution, and must the intervening act be the sole proximate cause of death to relieve the defendant of liability?
2. Did the trial court err by excluding all evidence and argument supporting Garcia’s superseding-cause theory and by preventing the jury from considering that theory?

## Decision

- The Iowa Supreme Court applied a “sole proximate cause” standard: an intervening act relieves a defendant of criminal responsibility only if it becomes the sole proximate cause of death.
- The Court held the trial court erred by categorically excluding Garcia’s superseding-cause evidence on the premise that the shooting and subsequent treatment necessarily remained concurrent proximate causes as a matter of law.
- The Court concluded that, on a properly developed record, whether the hospital conduct could be found to be the sole proximate cause was for the jury to decide.
- The Court sustained the reversal of the conviction in substance and remanded for further proceedings consistent with its causation analysis.

## Legal Principles

- In Iowa homicide prosecutions, the State must prove the defendant’s conduct was a proximate cause of death; it need not be the only cause.
- An intervening act breaks the causal chain and relieves criminal responsibility only if the intervening act is the sole proximate cause of death.
- Medical treatment following a violent injury is ordinarily a foreseeable consequence and does not sever causation merely because it is negligent; only extraordinary and independent treatment that could be found to be the sole proximate cause may do so.
- When reasonable factfinders could differ on whether an intervening act was the sole proximate cause, causation is a factual question for the jury, and the defense must be allowed to present competent evidence supporting the theory.

## Conclusion

The Iowa Supreme Court held that intervening medical negligence can exonerate a homicide defendant only if it is the sole proximate cause of death, and it required that the jury be permitted to hear and assess competent evidence supporting a superseding-cause defense rather than having the issue resolved categorically as a matter of law.


State v. Garcia, 616 N.W.2d 594 (Iowa 2000)