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embolism that caused her death).” Accord, Johnson v. State , 295 Ga. 421, 761 S.E.2d 13 (June 30, 2014) (intervening medical care didn’t prevent defendant’s violent attack from being cause of death). Currier v. State, 294 Ga. 392, 754 S.E.2d 17 (January 21, 2014). Felony murder and related convictions affirmed; “a rational trier of fact was authorized to find appellant guilty beyond a reasonable doubt of felony murder in spite of the fact that the medical cause of death was undeterminable due to the body's decomposition.” “When construing Georgia's felony murder statute,[fn] this Court has held that causing the death of another human being means proximate causation. State v. Jackson, 287 Ga. 646(2) (697 S.E.2d 757) (2010). ‘Proximate causation imposes liability for the reasonably foreseeable results of criminal ... conduct if there is no sufficient, independent, and unforeseen intervening cause.’ Id. at 654. We consider the elements of the felony not in the abstract, but in the actual circumstances in which the felony was committed. Davis v. State, 290 Ga. 757, 760(4) (725 S.E.2d 280) (2012). Here it was reasonable to foresee that the victim could be fatally wounded upon receiving a beating from which he could not extricate himself because he was being held in place by appellant. The medical examiner's testimony was only one aspect of the State's case and could not be considered in isolation.” Accord, Franklin v. State , 295 Ga. 204, 758 S.E.2d 813 (May 19, 2014); Wilson v. State , 297 Ga. 86, 772 S.E.2d 689 (May 11, 2015). Browder v. State, 294 Ga. 188, 751 S.E.2d 354 (November 18, 2013). Murder and related convictions affirmed; evidence supported finding that shooting was cause of death. “Browder asserts the evidence did not establish the victim was legally dead at the time life support systems were disconnected and thus the evidence was insufficient to establish the victim's gunshot injury to be the efficient, proximate cause of death. We disagree. Expert testimony established that the victim died as the result of an inability to breathe which was the result of injuries sustained from the gunshot wound. Because the injuries were such that the victim could not live once life support systems were removed, the evidence was sufficient to authorize the jury to find the victim died as a result of the injuries inflicted by Browder. See Phillips v. State, 280 Ga. 728, 729(1), 632 S.E.2d 131 (2006) (evidence sufficient to support conviction for murder where the victim's brain injuries were such that he could not live when taken off life support). See also Hicks v. State, 285 Ga. 386(1), 677 S.E.2d 111 (2009) (evidence sufficient to support conviction where the forensic pathologist determined the victim's death after life support equipment was removed to be the result of complications from a physical assault).” Dodson v. State, 292 Ga. 790, 741 S.E.2d 639 (April 15, 2013). Malice murder conviction affirmed; evidence was sufficient to show that defendant’s assault caused victim’s death notwithstanding intervening medical issues. Elderly victim had surgery on his broken skull; he died from sepsis 47 days later when his feeding tube became dislodged. “[I]t was for the jury to determine the cause of Wright's death, and the jury understandably resolved the issue of causation adversely to Dodson. See Shields v. State, 285 Ga. 372, 374(1) (677 S.E.2d 100) (2009). See also Green v. State, 266 Ga. 758, 759(2)(b) (470 S.E.2d 884) (1996) (an ‘unlawful injury may be the cause of death if the injury directly and materially contributed to the happening of a secondary or consequential cause of death.’) (punctuation and footnote omitted). Evidence was presented to the jury that elderly and bedridden patients such as Wright often die as a result of pneumonia or infections that they develop during their treatment, such as infections from a dislodged feeding tube. And while Dodson blames Wright's caregivers for failing to notice in a timely manner that Wright's feeding tube had become dislodged, the evidence shows that it was because of the brain injuries inflicted upon Wright by Dodson that a feeding tube was required and that Wright was unable to inform anyone when the tube became dislodged. ” Clarke v. State, 292 Ga. 305, 737 S.E.2d 575 (January 7, 2013). Malice murder and related convictions affirmed; evidence was sufficient to support finding that defendant’s violent attack, striking elderly victim on the head with a large board, caused her death. “After the trauma team stabilized [victim] Toles, she was transferred to an acute care nursing facility. Toles had difficulty breathing due, in part, to her mouth being wired shut, so a tracheotomy had to be performed on her. Doctors discovered that she was also suffering from severe sepsis, necrotic bowels, a urinary tract infection, shock, and respiratory failure; however, her condition was exacerbated by the fact that she had been bedridden since the time of the attack. The victim's advanced age contributed to her inability to recover from the attack. And, even though her autopsy revealed other medical conditions including cardiovascular disease, the medical examiner determined that the cause of Toles's death was delayed complications from the blunt force trauma to her head; he testified that as a 74–year–old woman, Toles had ‘a lot of natural disease processes,’ but that her head injury was the underlying process that ‘started the ball rolling’ in a ‘continuous downhill course,’ culminating in her death. Contrary to Clarke's assertion, the medical examiner's conclusion about the cause of death was not premised upon speculation; he testified in great detail about the factual basis for his opinion of the cause of death of the victim. Further, the medical examiner's testimony about the manner of the victim's death being a homicide did not improperly invade the province of the jury on the ultimate issue of criminal liability. Sharpe v. State, 291 Ga. 148, 150(2) (728 S.E.2d 217) (2012).” Accord, Dyer v.
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