Comber v. United States

584 A.2d 26 (1990)

Facts

Comber (D) punched Pinkney once or twice in the face. Pinkney was extremely intoxicated at the time and fell down and died. The autopsy revealed that Pinkney's death was caused from subarachnoid brain hemorrhaging from forceful blows to the head. There was no evidence that the death resulted from Pinkney falling down. Hayward (D1) struck Butler in the jaw and Butler fell into the street and hit his head and lost consciousness. A short time later Butler regained consciousness, and once again, D1 and Butler were at it and D1 again punched Butler in the jaw and Butler was again knocked to the ground, lost consciousness and died later that morning at the hospital. The medical evidence showed that Butler had died from the fall when he hit the ground. These appeals were consolidated to determine if the jury instructions for the crime of manslaughter are appropriate when a person dies as a result of bare-fisted blows to the face.