## Facts

- Richard Robert Sauter, intoxicated and during an altercation, stabbed Matt Charles Lines.
- Lines was taken to a Phoenix hospital, where a surgeon performed abdominal surgery repairing multiple internal injuries, including stomach wall lacerations and damage to major arteries and pancreatic tissue.
- The surgeon palpated the abdominal aorta but did not detect or repair a one-inch laceration.
- Lines continued to lose significant blood after surgery.
- An autopsy determined Lines died from blood loss, principally from the unrepaired aortic laceration.
- At trial, Sauter sought to introduce evidence that the surgeon’s failure to find and repair the aortic injury constituted intervening medical malpractice.

## Issues

1. Whether alleged medical malpractice in failing to discover and repair the victim’s aortic laceration broke causation so Sauter could be guilty only of assault rather than homicide.
2. Whether the trial court erred by excluding evidence of the surgeon’s alleged malpractice offered to negate causation for voluntary manslaughter.

## Decision

- The Arizona Supreme Court affirmed Sauter’s voluntary manslaughter conviction.
- The court held the surgeon’s failure to discover and repair the aortic laceration did not break the causal chain from the stabbing to the death.
- Because the stabbing inflicted a life-endangering wound and any malpractice was not the sole cause of death, evidence of the alleged malpractice was properly excluded as legally irrelevant.

## Legal Principles

- When a defendant unlawfully inflicts a wound calculated to endanger life, it is not a defense to homicide that the victim might have survived with more skillful medical treatment.
- Medical malpractice severs causation and becomes the proximate cause of death only if it constitutes the sole cause of death.
- If the original criminal act remains an operative cause of death, contributory or negligent medical treatment does not relieve the assailant of homicide liability.

## Conclusion

The court held that a defendant who inflicts a dangerous, life-threatening wound remains criminally responsible for the victim’s death despite later negligent medical treatment, unless the malpractice is the sole cause of death; accordingly, excluding malpractice evidence and affirming the manslaughter conviction were proper.


State v. Sauter, 120 Ariz. 222, 585 P.2d 242 (Ariz. 1978)