New Hampshire v. Hutchinson
Annotate this CaseFollowing a jury trial, Defendant Walter Hutchinson, Jr. was convicted of first-degree murder for the killing of his former girlfriend Kimberly Ernest. He was sentenced to life in prison without the possibility of parole. On appeal, he argued that the trial court erred in denying his motion to dismiss for insufficient evidence on “causation” of Ernest’s death. On October 8, 1991, a jury found Defendant guilty of attempted murder for beating and strangling Ernest. In the attack, she sustained severe brain damage. Ernest’s family chose to treat her only with comfort measures. She died from her injuries. The State brought murder charges against the defendant. Defendant sought to have the charges against him thrown out, and appealed the trial court’s denial of his motion to dismiss. On appeal, Defendant asserts that the evidence was insufficient to prove he caused Ernest’s death. He did not contest that his actions caused her permanent brain injury; rather, Defendant argues that the risks to Ernest’s health as a result of his actions did not establish the necessary element of legal causation. Upon review, the Supreme Court concluded that the evidence in this case was sufficient to support the jury’s finding that Defendant’s conduct caused Ernest’s death beyond a reasonable doubt. The Court affirmed the lower court’s decision to deny Defendant his motion to dismiss.
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