State v. Dominguez, 1 CA-CR 16-0845

On Sept. 8, 2015, Dominguez exposed himself and later approached a dental-office employee; she called police and identified him.
Three Tempe officers attempted to arrest Dominguez; during the arrest he resisted, rolled, and disconnected multiple Taser deployments.
A physical struggle occurred in which officers fell, an officer struck Dominguez, and ultimately the officers subdued and handcuffed him.
After the arrest an officer was diagnosed with a sprained wrist and missed work; Dominguez was indicted for aggravated assault on a peace officer, resisting arrest, and indecent exposure.
At trial the jury was instructed on elements of aggravated assault and resisting arrest (no separate causation instruction); the jury convicted on all counts.
On appeal Dominguez argued insufficient evidence of causation for aggravated assault because the officer’s injury resulted from the officer’s own striking, not Dominguez’s conduct.

Issue	Plaintiff's Argument	Defendant's Argument	Held
But‑for causation: whether Dominguez’s resistance was a but‑for cause of the officer’s wrist injury	State: but for Dominguez’s resisting, officers would not have used force and injury would not have occurred	Dominguez: officer’s voluntary decision to strike caused the injury, not his resistance	Held: Sufficient evidence for jury to find but‑for causation — resistance set in motion the struggle that produced the injury
Proximate causation / superseding intervening act: whether the officer’s act of striking was an unforeseeable superseding cause	State: officer’s response was a foreseeable response to resistance; various injuries to officers during a struggle are foreseeable	Dominguez: officer’s deliberate striking was an abnormal, superseding act that broke the causal chain	Held: Court affirmed proximate causation — officer’s conduct was not an extraordinary superseding act; resistance foreseeably exposed officers to injury, so Dominguez can be held liable

State v. West, 226 Ariz. 559 (discussing de novo review and sufficiency standard)
State v. Mathers, 165 Ariz. 64 (sufficiency standard for convictions)
State v. Marty, 166 Ariz. 233 (but‑for and proximate cause required in criminal cases)
State v. Bass, 198 Ariz. 571 (criminal standard for superseding cause parallels tort standard)
Petolicchio v. Santa Cruz Cty. Fair & Rodeo Ass'n, Inc., 177 Ariz. 256 (defendant liable if actions increased foreseeable risk of harm)
Ring v. Arizona, 536 U.S. 584 (causation is an element for the jury to decide)
United States v. Pineda‑Doval, 614 F.3d 1019 (officer’s response to defendant’s conduct not an extraordinary superseding cause)