Motions and Briefs

Addresses public health consequences of laws creating criminal liability for accidental drug overdose and provides research supporting the following conclusions:

Affidavit of Jennifer Carroll, PhD, MPH, MARead More

Addresses defendant’s motion to dismiss where evidence on causation was insufficient, failure to instruct the jury on intervening acts of others, failure to instruct the jury on lesser included offense of involuntary manslaughter when the evidence of malice was in conflict, and court’s failure to intervene in state’s closing argument. Reply Brief filed in June …

Appellant Reply Brief in State v. AndersonRead More

Appellant’s Brief addressing trial court’s denial of defendant’s motion to dismiss where the state did not prove the defendant’s actions proximately caused the decedents’ deaths and another individual’s actions were a superseding cause of the decedents’ deaths which broke the chain of causation. Also addresses trial court’s failure to instruct on whether intentional acts by …

Appellant Brief in State v. AndersonRead More

Addresses complex chain of causation, proximate cause, identify of the controlled substance, and cause of death. Brief filed in Aug. 2023 in 2020 case.

Appellant Brief in State v. McCroreyRead More