People v. Tims

i

The cases before us raise the issue of criminal proximate cause in criminal negligence cases. In each case, the Court of Appeals reversed the defendant’s conviction because the trier of fact did not address whether the defendant’s conduct was *111"the” proximate cause.1 We agree with both defendants that finding that the defendant’s conduct was "a” substantial factor, which is the civil law causation standard, is insufficient in a criminal negligence case. We believe that criminal liability requires a more direct causal connection than merely finding that the defendant’s actions were "a” cause.…