Blaize v. United States

Summary

The District of Columbia Court of Appeals affirmed Marlon Blaize’s convictions for voluntary manslaughter while armed, assault with a dangerous weapon, carrying a pistol without a license, and two firearm-during-a-crime-of-violence offenses. The court held that the causation instruction adequately addressed foreseeability, that the evidence supported finding Blaize’s gunfire was a proximate cause of the victim’s death after being struck by a fleeing vehicle, that the medical examiner’s testimony was admissible, and that the two firearm convictions did not merge.

Holdings

1. The causation instruction given by the trial court adequately conveyed that Blaize could not be held responsible if Miller's death was not a reasonably foreseeable consequence of Blaize's conduct; therefore, the court committed no plain error by not giving a more specific intervening-cause instruction.
2. The evidence was sufficient for the jury to find that Blaize's firing in Miller's direction was a substantial factor in causing Miller's death and that the fatal chain of events was reasonably foreseeable.
3. The trial court did not abuse its discretion by admitting the medical examiner's testimony concerning the medical classification of Miller's death and the circumstances relevant to that classification.
4. The two PFCV convictions did not merge because the predicate offenses arose from separate criminal impulses and constituted distinct violent crimes.

Questions Presented

1. Whether the trial court plainly erred by failing to give a separate instruction on intervening or superseding cause and proximate cause.
2. Whether the evidence was sufficient to establish that Blaize's firing of the gun was the proximate cause of Miller's death.
3. Whether the trial court abused its discretion by admitting the medical examiner's testimony concerning the classification and cause of Miller's death.
4. Whether Blaize's two PFCV convictions, predicated on assault with a dangerous weapon and voluntary manslaughter, merged because they involved one firearm and one victim.

Disposition

affirmed