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State v. McFadden
Supreme Court of Iowa (1982)
Defendant: McFadden; the defendant and the deceased were involved in drag racing and during the race, the deceased went on the wrong side of the road and got in a head on collission with a car which also resulted in the death of a six year old innocent passenger. The defendant was charged with two counts of involuntary manslaughter and now the he appeals and argues that under Commonwealth v. Root, his actions did not have sufficient causal relationship with the actions of the deceased.
Issue: Did the defendant's reckless actions proximately caused the death of the deceased and the innocent victim making him responsible for those deaths?
Holding: Yes
Legal Reasoning: The court held that a reasonable person would clearly foresee that drag racing on city streets is highly dangerous. The court held that wherever there is foreseeability and recklessness involved, the defendant can be held proximately responsible. The court rejected the judgement of Root and the conviction was affirmed.