State v. Below, 799 N.W.2d 95

Below appeals a conviction for first-degree reckless homicide and physical abuse of a child related to Madison Below's August 2008 death.
Evidence showed Below repeatedly struck Madison's head against a changing table, causing severe brain injury and death.
Medical testimony linked the injuries to an overwhelming brain injury, with skull fracture and other head injuries indicating substantial force.
The State admitted life-support was terminated, but the trial court denied Below's request for an intervening-cause instruction.
The jury found Below guilty; the trial court entered judgment, and Below challenged the denial of the intervening-cause instruction on appeal.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Intervening cause instruction	Below argues the instruction was required due to life-support termination	Below contends intervening act breaks causation	Instruction not required; causation shown by substantial-factor test
Sufficiency of evidence	Evidence shows Below's acts were a substantial factor in death	Uncertain whether death was caused by acts given life-support termination	Sufficient evidence beyond reasonable doubt to convict

State v. Oimen, 184 Wis. 2d 423 (1994) (substantial-factor causation framework for death)
Cranmore v. State, 85 Wis. 2d 722 (Wis. Ct. App. 1978) (causation unaffected by subsequent medical negligence; substantial-factor test suffices)
State v. Serebin, 119 Wis. 2d 837 (Wis. Ct. App. 1984) (chain-of-causation in homicide cases)
State v. Glenn, 190 Wis. 2d 155 (Wis. Ct. App. 1994) (credibility and weighing of evidence by trier of fact)
State v. Block, 170 Wis. 2d 676 (Wis. Ct. App. 1992) (standards for appellate review of factual inferences)
State v. Poellinger, 153 Wis. 2d 493 (Wis. 1990) (standard of review for sufficiency of evidence)
State v. Tarantino, 157 Wis. 2d 199 (Wis. Ct. App. 1999) (application of sufficiency and causation principles)
Cook v. Cook, 208 Wis. 2d 166 (Wis. 1997) (precedent on causation and responsibility)