## Facts

- Joseph Sandridge and his cousin, Melvin Logan, spent an evening drinking and argued.
- During the dispute, Sandridge struck Logan in the back of the head with a lead pipe.
- Logan survived the initial assault but later suffered serious medical consequences.
- About 23 months after the assault, Logan died.
- The coroner attributed Logan’s death to post-traumatic epilepsy caused by the head injury from the assault.
- After Logan’s death, the State indicted Sandridge for voluntary manslaughter.

## Issues

1. Whether Ohio recognized the common-law year-and-a-day rule as a bar to homicide liability when the victim dies more than a year and a day after the injury.
2. Whether a voluntary-manslaughter indictment must be dismissed when the victim’s death occurs about 23 months after the alleged fatal assault.

## Decision

- The Court of Common Pleas denied Sandridge’s motion to dismiss the indictment.
- The court permitted the prosecution to proceed despite the delay between the injury and death.
- The court concluded the year-and-a-day rule did not control in these circumstances, given Ohio’s statutory homicide framework and the availability of medical proof of causation.

## Legal Principles

- The year-and-a-day rule is a common-law temporal limitation on homicide causation, historically tied to evidentiary uncertainty about remote causes of death.
- Under Ohio’s statutory scheme, homicide liability turns on proof of causation beyond a reasonable doubt, not an automatic time cutoff not expressed in the statutes.
- When competent medical evidence can link the defendant’s act to the victim’s later death, the causation question is for the factfinder rather than being foreclosed by an arbitrary timing presumption.

## Conclusion

The court refused to apply the year-and-a-day rule to dismiss a voluntary-manslaughter indictment where the victim died nearly two years after the assault, holding that the case should proceed on ordinary proof of causation supported by medical evidence.


State v. Sandridge, 365 N.E.2d 898 (Ohio Ct. Com. Pl. 1977)