People v. OlloAnnotate this Case
A defendant's act of furnishing drugs and the user's voluntary act of ingesting them constitute concurrent direct causes, such that the defendant who so furnishes personally inflicts great bodily injury upon his victim when she subsequently dies from an overdose. In this case, defendant was found guilty of furnishing or giving drugs to his girlfriend, and the jury found true the allegation that he had personally inflicted great bodily injury upon her.
The Court of Appeal affirmed and held that, because the victim's voluntary ingestion of the drugs furnished by defendant did not absolve him of his direct causal role in her injury, the argument that it did was contrary to the law and was properly barred by the trial court. The court agreed with People v. Martinez (2014) 226 Cal.App.4th 1169, and rejected People v. Slough (2017) 11 Cal.App.5th 419. Finally, the court rejected defendant's contention that the trial court erred in imposing the upper-term sentence; defendant's due process-based arguments under People v. Dueñas (2019) 30 Cal.App.5th 1157; and defendant's argument that the $370 in monetary obligations constitutes cruel and unusual punishment.