State v. Crawford, 2022 Ohio 1509

Late-night altercation after a party in Cleveland ended in Gary Dickens’s death by gunfire; multiple witnesses placed Jeremy Crawford at the scene and testified Crawford fired a gun during the incident.
Crawford was legally prohibited from possessing firearms because of a prior drug-related conviction (weapons-while-under-disability).
Indictment included counts for unlawful discharge of a firearm, felony murder (predicated on unlawful discharge), weapons-while-under-disability, and involuntary manslaughter (predicated on weapons-while-under-disability).
Jury convicted Crawford of weapons-while-under-disability and involuntary manslaughter; it acquitted him of felony murder and found that his discharge did not cause serious physical harm.
On appeal, Crawford argued as a legal matter that a weapons-while-under-disability felony cannot serve as the predicate for involuntary manslaughter unless the underlying reason for the disability (his prior drug offense) was causally related to the death.
The Ohio Eighth District affirmed; the Ohio Supreme Court accepted review and affirmed the conviction, rejecting Crawford’s legal theory.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a weapons-while-under-disability felony can serve as the predicate for involuntary manslaughter when the reason for the disability is unrelated to the victim’s death	Crawford: The disability’s underlying cause must be causally connected to the death for the predicate felony to qualify	State: R.C. 2903.04(A) requires only that a felony be committed and the death be a proximate result of that felony; no link between the disability’s reason and the death is required	Affirmed. The statute requires proximate causation between the felony conduct and death; it does not require the reason for the disability be causally related to the death

State v. Carpenter, 128 N.E.3d 857 (Ohio App. 2019) (discussing proximate-result language in involuntary manslaughter context)
State v. Owens, 166 N.E.3d 1142 (Ohio 2020) (recognizing symmetry between proximate-cause language in related statutes)
Robers v. United States, 572 U.S. 639 (U.S. 2014) (proximate-cause inquiry asks whether harm has sufficiently close connection to defendant’s conduct)
Lexmark International, Inc. v. Static Control Components, Inc., 572 U.S. 118 (U.S. 2014) (framework for proximate-cause analysis in civil context referenced for principle of close connection)
Johnson v. University Hospitals of Cleveland, 540 N.E.2d 1370 (Ohio 1989) (foreseeability is central to proximate-cause analysis)