Melancon v. State

Summary

The court clarified that causation under Georgia’s murder statute has two required components: cause in fact and legal cause. It held that the evidence did not establish either component under the theory that Melancon caused the child’s death by stopping his girlfriend from cooperating with DFCS, because the asserted causal chain depended on speculation about what DFCS would have done and whether the later fatal abuse was a probable consequence. The court vacated the Court of Appeals’ judgment and remanded for consideration of the State’s other causation theories.