## Facts

- Michael Dwayne McFadden and Matthew Sulgrove engaged in an illegal drag race on a public street in Des Moines, Iowa.
- During the race, Sulgrove lost control, crossed into oncoming traffic, and collided with a lawfully operated northbound vehicle.
- The collision killed Sulgrove and a six-year-old passenger in the other vehicle, Faith Ellis.
- McFadden’s vehicle did not strike either vehicle involved in the collision.
- The State charged McFadden with two counts of involuntary manslaughter under Iowa Code § 707.5(1) (1979), premised on underlying public offenses of reckless driving and drag racing.
- McFadden waived a jury and was convicted after a bench trial.
- The trial court relied on three alternative theories: aiding and abetting, joint criminal conduct, and McFadden’s own reckless conduct as a proximate cause of death.

## Issues

1. Whether a drag racer can “unintentionally cause[] the death” required for involuntary manslaughter when his vehicle did not physically contact the victims’ vehicle.
2. Whether civil-law concepts of proximate cause (including foreseeability and substantial-factor causation) may be used to prove causation in criminal involuntary manslaughter.
3. Whether the co-racer’s voluntary participation and independent reckless driving broke the causal chain as to the defendant.
4. Whether the sentencing court erred by failing to state on the record reasons for the specific sentences imposed.

## Decision

- The Iowa Supreme Court affirmed McFadden’s two involuntary manslaughter convictions.
- The court held the evidence supported a finding that McFadden’s participation in the drag race was a proximate cause of the deaths, despite the absence of physical contact.
- The court approved use of civil proximate-cause analysis to satisfy the statutory causation requirement.
- The court rejected the argument that Sulgrove’s voluntary participation and loss of control relieved McFadden of liability.
- The court vacated the sentences and remanded for resentencing because the trial court did not state reasons for the selected sentences on the record.

## Legal Principles

- In involuntary manslaughter predicated on commission of a nonforcible public offense, the State must prove the defendant’s conduct was a legal cause of death; Iowa permits proximate-cause analysis to satisfy that element.
- A defendant may be criminally liable for a resulting death without direct physical contact if his conduct was a substantial factor and the fatal harm was a foreseeable consequence of the unlawful, reckless activity.
- Joint participation in an illegal, dangerous enterprise (such as drag racing on public roads) can support liability for resulting deaths under aiding-and-abetting and joint-criminal-conduct theories, as well as direct causation, when the deaths are a foreseeable result of the joint activity.
- A sentencing court must state reasons on the record for the particular sentence imposed; failure to do so requires vacatur of the sentence and remand for resentencing.

## Conclusion

The court held that participating in an illegal street race can proximately cause deaths caused by a co-racer’s loss of control even absent vehicle contact, and it affirmed the manslaughter convictions while vacating the sentences for failure to state sentencing reasons on the record.


State v. McFadden, 320 N.W.2d 608 (Iowa 1982)