People v. Butler

Stephen Butler appeals from a judgment convicting him of involuntary manslaughter. He asserts there is insufficient evidence to support a finding that his conduct caused the victim’s death, and the trial court erred in failing to instruct the jury on criminal negligence. We reject these contentions and affirm the judgment.

OVERVIEW

The charges against defendant arose from an incident during which he and other individuals beat, tied up, suffocated and provided cocaine to the victim. Based on defendant’s participation, he was charged with various offenses, including first degree felony murder, second degree murder, and false imprisonment by violence or menace. With respect to the homicide allegations, the jury was instructed on murder and on involuntary manslaughter as a lesser offense. The jury was also instructed that the predicate offenses underlying the involuntary manslaughter charge were furnishing cocaine, battery, and false imprisonment by violence or menace. The jury rejected the murder charges, was unable to reach a verdict on the false imprisonment allegation, and found defendant guilty of involuntary manslaughter.

Defendant’s contentions on appeal concern…