Elizabeth A. Campbell

The Court considered whether an intervening assault by a bar bouncer could sever legal causation after the appellants had already violently assaulted the victim, who later died.

It held that legal causation remains governed by whether the accused's dangerous unlawful acts were a significant contributing cause of death, and that foreseeability and independence are analytical tools, not standalone legal tests.

On the trial judge's factual findings, it was open to conclude the bouncer's conduct was a reasonably foreseeable response in an escalating bar fight and not sufficiently independent to break the causal chain.

The Court therefore upheld the result that the appellants could legally be found to have caused death and dismissed the appeal.

The appellant challenged a conviction for sexual assault, arguing error in admitting a prior sexual-assault conviction as similar fact evidence on identity and in restricting a voir dire challenge to that prior verdict.

The Court held that a prior conviction can constitute reliable 'some evidence' linking an accused to similar act conduct when identity is put in issue.

It further held that while challenges to prior convictions are not categorically barred at the voir dire stage, they may be limited where there is no reasonable likelihood of affecting admissibility.

The Court found no reversible error in the trial judge's admissibility ruling or ultimate identity finding on the trial record.