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State v. Christman
249 P.3d 680
Wash. Ct. App.
2011
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Background

  • 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)
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Case Details

Case Name: State v. Christman
Court Name: Court of Appeals of Washington
Date Published: Mar 17, 2011
Citation: 249 P.3d 680
Docket Number: 28609-6-III
Court Abbreviation: Wash. Ct. App.