State v. Christman
249 P.3d 680
Wash. Ct. App.2011Background
- Christman delivered methadone pills to Mulder at a party; Mulder later used them and died from a combination of methadone, methamphetamine, and alcohol.
- The medical examiner could not isolate methadone as the sole cause of death; other substances contributed to the death.
- Mulder’s blood tested by the state toxicology lab showed .23 mg/L methadone; amounts of alcohol and methamphetamine were not quantified in that sample.
- The State charged Christman with controlled substances homicide, alleging delivery of a controlled substance resulting in death.
- Jury instructions defined required elements, including that the use of the delivered substance resulted in death; no proximate cause instruction was given.
- Christman challenged the conviction on proximate-cause grounds and on vagueness of the statute RCW 69.50.415.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether proximate cause is required for RCW 69.50.415 | Christman: 'results in' requires proximate cause. | Christman: same; statute ambiguous about causation. | Proximate cause required; 'results in' construed to require proximate cause. |
| Whether RCW 69.50.415 is unconstitutionally vague as applied | Christman: ambiguity permits arbitrary enforcement. | Christman: statute vague under both aspects of vagueness doctrine. | Statute not unconstitutionally vague as applied; well-settled meaning supports causation requirement. |
| Whether evidence supports causation and the conviction | State: methadone caused death in medical causation sense. | Christman: death not solely caused by methadone; insufficient causation. | Evidence sufficient; methadone proximate cause; concurrency with other factors permissible. |
Key Cases Cited
- State v. Armendariz, 160 Wash.2d 106 (2007) (de novo review of statutory interpretation; proximate-cause standard discussed)
- State v. Neher, 112 Wash.2d 347 (1989) (statutory interpretation and use of common-law definitions)
- State v. Leech, 114 Wash.2d 700 (1990) (foreseeability and proximate-cause concepts in Washington law)
- State v. Berube, 150 Wash.2d 498 (2003) (proximate cause in homicide statutes; need for causation proof)
- State v. Little, 57 Wash.2d 516 (1961) (causal connection as element of corpus delicti in death offenses)
- State v. Perez-Cervantes, 141 Wash.2d 468 (2000) (discusses cause in fact and legal causation in context of death)
- Hartley v. State, 103 Wash.2d 768 (1985) (proximate causation as policy-laden; broad view of liability)
- State v. Meekins, 125 Wash.App. 390 (2005) (multiple proximate causes and concurrent causation recognized)
- State v. Douglass, 115 Wash.2d 171 (1990) (vagueness doctrine and fair warning considerations)
