State of Iowa v. Cornell Miller, 874 N.W.2d 659

Miller was convicted of delivery of a controlled substance and involuntary manslaughter as a habitual offender; he challenges only the manslaughter conviction and causation instruction.
On 9/11/2013 Miller sold three doses of heroin to Delong and Hansen, who ingested them together and subsequently died of combined alcohol and heroin intoxication.
Hansen had several health issues; autopsy showed multiple medical conditions and that death was from combined alcohol and heroin intoxication.
Delong identified Miller as the heroin source; police searched Miller’s residence; he was arrested and charged with involuntary manslaughter and drug delivery.
At trial Miller argued the heroin injection by Delong was an intervening, superseding cause; the court did not give a causation instruction and Miller obtained no causation instruction otherwise.
The jury found Miller guilty; Miller stipulated to the habitual-offender enhancement and the district court imposed a 15-year indeterminate term; appeal followed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether there is sufficient evidence of recklessness	Miller contends evidence shows recklessness given heroin’s danger and quantities sold.	Miller argues the State failed to prove both heightened risk and defendant’s subjective awareness of that risk.	Insufficient evidence of recklessness; conviction reversed.
Whether the trial court erred by not giving a causation instruction or intervening-cause instruction	Miller requested an intervening-cause causation instruction; district court refused and gave none.	State contends standard causation is met by the underlying offense; no need for extra instruction.	Issue moot after reversal; conviction on involuntary manslaughter vacated and remanded for acquittal on that count.

State v. Conner, 292 N.W.2d 682 (Iowa 1980) (recklessness required as component of involuntary manslaughter)
State v. Torres, 495 N.W.2d 678 (Iowa 1993) (two aspects of recklessness: probability of harm and culpability for harm)
State v. Ayers, 478 N.W.2d 606 (Iowa 1991) (underlying public offense must be committed recklessly)
State v. Kernes, 262 N.W.2d 602 (Iowa 1978) (culpable conduct requires proof of recklessness)
Lofthouse v. Commonwealth, 13 S.W.3d 236 (Ky. 2000) (reversed per se recklessness approach; must prove substantial and unjustifiable risk beyond mere drug toxicology facts)
State v. Caldwell, 385 N.W.2d 553 (Iowa 1986) (recklessness may be shown by awareness of risk; not just high danger standard)