People of Michigan v. Travis Lamar Hudson, 330603

Background

On Sept. 28, 2014, Hudson used a phone-tracking app, traced a phone to Armon Parker’s home, and went to the residence seeking the phone; an encounter with Steffon Causey escalated.
Hudson entered the house, produced a loaded handgun during a confrontation about who would go down the stairs first; he testified he did not intend to shoot and did not have his hand on the trigger.
Causey rushed Hudson, grabbed for the gun, and a struggle ensued; the gun discharged while both men had hands on it, striking Causey; Causey later died of the wound.
Hudson pleaded guilty to related weapons offenses; at trial he was convicted by a jury of involuntary manslaughter and felony-firearm and was sentenced as a fourth habitual offender to lengthy prison terms.
On appeal Hudson argued the trial court erred by not giving a jury instruction (M Crim JI 16.20) on the victim’s contributory negligence/ proximate-cause as an intervening act that could sever causation.
The court considered whether omission of that instruction was plain or preserved error and whether Causey’s acts could be deemed a superseding, unforeseeable intervening cause that would break the causal chain.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred by failing to give an instruction on victim contributory negligence (M Crim JI 16.20) relevant to proximate causation	Prosecution: no additional instruction required because defendant’s conduct was a factual and proximate cause; Causey’s reaction was foreseeable	Hudson: omission prejudiced him because Causey’s rushing/grabbing was negligent or an intervening act that could break causation	Court: No reversible error — evidence did not support that Causey’s acts were an unforeseeable superseding cause; omission did not affect substantial rights
Whether the jury needed a specific instruction explaining factual and proximate causation (M Crim JI 16.15)	Prosecution: existing instructions and elements were given, and the evidence plainly established causation	Hudson: jury should have been instructed that causation requires both factual and proximate causation and that victim negligence is considered	Court: trial court did not give M Crim JI 16.15 but provided elements under M Crim JI 16.10; any omission was not outcome-determinative given the evidence
Standard of review for instructional error	N/A	N/A	Preserved general causation claim reviewed de novo; unpreserved failure to give M Crim JI 16.20 reviewed for plain error under Carines; harmless-error principles apply under Dupree/Kowalski
Whether victim negligence can exonerate defendant where defendant’s act was a proximate cause	Prosecution: victim negligence is not a defense but may be considered in proximate-cause analysis	Hudson: victim’s grabbing could be treated as contributory negligence breaking the causal chain	Court: Victim’s ordinary negligence is foreseeable and insufficient to break proximate causation; only gross negligence/intentional misconduct would generally do so

Key Cases Cited

People v Feezel, 486 Mich 184 (explains need to instruct jury on factual and proximate causation and foreseeability in superseding-cause analysis)
People v Schaefer, 473 Mich 418 (explains that ‘‘cause’’ is a legal term requiring instruction on factual and proximate causation)
People v Tims, 449 Mich 83 (defines involuntary manslaughter and the causation component)
People v Bailey, 451 Mich 657 (holds contributory cause does not necessarily sever liability; proximate cause may be shared)
People v Kowalski, 489 Mich 488 (imperfect instructions may be harmless where elements adequately presented and evidence overwhelming)
People v Carines, 460 Mich 750 (plain-error standard for unpreserved trial errors)
People v Dupree, 486 Mich 693 (harmless-error/ outcome-determinative standard for preserved nonconstitutional errors)