In reviewing a murder conviction, the Washington court recently was confronted with the problem of negligent medical treatment intervening between the defendant's act and the ensuing death. In affirming, the court apparently took the extreme position that proximate causation is solely a jury question, the inquiry on appeal being limited to a cause-in-fact analysis.
Charles B. Cooper,
Washington Case Law,
Criminal Law—Murder—Negligent Medical Treatment Intervening Between Defendant's Act and Decedent's Death,
37 Wash. L. Rev.
Available at: https://digitalcommons.law.uw.edu/wlr/vol37/iss2/8