State v. Smith, 835 N.W.2d 1

Eddie Cortez Smith was convicted by jury of criminal vehicular homicide under Minn. Stat. § 609.21 for Edith Schouveller's death.
Schouveller, age 93, died following injuries from a head-on collision caused by Smith traveling at high speed and with a BAC of 0.11.
The collision occurred on Milton Street in Saint Paul; expert estimated Smith's speed at least 53 mph in a 30 mph zone.
Schouveller's medical condition deteriorated after the crash, including trauma to the brain and neck, leading to deconditioning and respiratory complications.
Doctors declined to resuscitate Schouveller under her living will's do-not-resuscitate provision, culminating in her death after acute respiratory failure.
Smith challenged causation, the jury instruction on causation/superseding cause, and whether the DNR order was a superseding cause; the court affirmed the conviction.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did the jury instruction on causation and superseding cause accurately state the law?	Smith argues the instruction was deficient for not tying superseding cause to causation.	Smith's position relies on the instruction's failure to explicitly negate causation where a superseding cause exists.	No error; instruction fairly stated law and instructed that a superseding cause defeats causation.
Was there sufficient evidence that Smith proximately caused Schouveller's death?	Proximate causation was required and Smith's acts must be substantial in causing death.	Evidence showed Smith's collision caused injuries leading to deconditioning and fatal complications.	Yes; evidence supported proximate causation of death by Smith's conduct.
Was the do-not-resuscitate order a superseding cause of death?	State argues DNR cannot be superseding; death would have occurred absent the DNR.	Smith contends DNR could be sole cause; trial court should have instructed for superseding cause.	No; the evidence supported that DNR was not the sole cause; proper to submit superseding-cause question to jury.

State v. Schaub, 231 Minn. 512 (1950) (proximate cause; 'cause of the cause' doctrine)
State v. Olson, 435 N.W.2d 530 (Minn.1989) (proximate cause; substantial-factor test)
State v. Gatson, 801 N.W.2d 134 (Minn.2011) (superseding-cause instruction proper when evidence supports single or multiple causes)
State v. Rounds, 160 A.2d 249 (Vt. 1932) (causation; 'cause of the cause' concept cited by Olson)
Regan v. Stromberg, 285 N.W.2d 97 (Minn.1979) (jury determination of superseding cause; reasonable minds may differ)
Lubbers v. Anderson, 539 N.W.2d 398 (Minn.1995) (proximate causation as jury question; standard of review)