Court: 6th Circuit Court (Published Opinions)
Attorneys:
ARGUED: Frank W. Heft, Jr., OFFICE OF THE FEDERAL DEFENDER, Louisville, Kentucky, for Appellant.
ARGUED: Terry M. Cushing, UNITED STATES ATTORNEY’S OFFICE, Louisville, Kentucky, for Appellee.
ON BRIEF: Frank W. Heft, Jr., Donald J. Meier, OFFICE OF THE FEDERAL DEFENDER, Louisville, Kentucky, for Appellant.
ON BRIEF: Monica Wheatley, UNITED STATES ATTORNEY’S OFFICE, Louisville, Kentucky, for Appellee.
Judge(s): CLAY, THAPAR, and NALBANDIAN, Circuit Judges
Court Appealed: United States District Court for the Western District of Kentucky at Bowling Green
NALBANDIAN, Circuit Judge. Some men just want to watch the world burn. Others start fires to collect insurance money. Steve Pritchard is the latter. But after playing with fire several times, Pritchard’s penchant for profiting from arson took a deadly turn. Instead of only damaging property, a fire started by Pritchard in June 2011 led to firefighter Charles Sparks’s death. While responding to the fire, Sparks suffered a fatal heart attack. Although Pritchard could have supposed that a firefighter would respond to the blaze, he had no reason to suspect that Charles Sparks would arrive on the scene, bringing with him a history of coronary disease and spotty use of his prescription medication. At issue is whether Pritchard caused Sparks’s death within the meaning of the federal arson statute, 18 U.S.C. § 844(i).
Pritchard’s appeal turns on first principles of causation. The common law typically permits liability only when the perpetrator acts as both the but-for and the legal cause of the harm. And that distinction often matters. Every fledgling law student knows that “a kingdom might be lost ‘all for the want of a horseshoe nail,’” see Massachusetts v. EPA, 549 U.S. 497, 546 (2007) (Roberts, C.J., dissenting), but we still don’t hold the blacksmith responsible for the defeat despite his faulty craftmanship’s role as the but-for cause. For that reason, laws that invoke proximate causation generally impose liability when the harm was foreseeable. Under 18 U.S.C. § 844(i), Sparks’s death need only be “a direct or proximate result of [Pritchard’s] conduct.” Because the government introduced testimony showing how firefighting can trigger a heart attack, we find that the jury had sufficient evidence to hold Pritchard responsible for Sparks’s death. Pritchard also alleges that the lower court committed various reversible errors, including wrongly admitting propensity evidence, denying his motion to suppress cell phone data seized by the government, and applying an unwarranted sentencing enhancement. Those arguments also lack merit. Thus, we AFFIRM.
pritchards_070720.pdf
