How have courts dealt with the issue of whether a defendant's conduct was a contributory factor in the death of a newborn baby?

On appeal, the defendant argued that the People failed to prove that his conduct caused the baby's death, which occurred due to natural causes one month after the baby's birth. (People v. Taylor, supra, 119 Cal.App.4th at p. 639.) Further the defendant argued that the baby's heart defect was a contributing factor to his death. (Ibid.) The appellate court noted, "even if the jury could have concluded that [the baby's] preexisting heart defect contributed to his death, that would not have relieved defendant of his responsibility for the death. As the courts have made clear, a defendant whose infliction of physical injury upon another is a cause of that person's death is guilty of unlawful homicide even if the injury was not the only cause of death, and even if the victim was in a weakened state due to a preexisting condition." (Id. at p. 641.) The court concluded, "the premature delivery [the beating] forced rendered him vulnerable to the condition that killed him." (Id. at p. 641.)

In People v. Butler (2010) 187 Cal.App.4th 998, the defendant and other individuals beat, tied up, suffocated and provided cocaine to the victim. The victim died and defendant was convicted of involuntary manslaughter. On appeal, the defendant argued that since the medical expert testified to four possible causes of deathblunt force trauma, restraint, asphyxiation and cocaine toxicityand could not decide on one, the evidence did not support that the defendant's actions were a substantial factor in causing the victim's death. (Id. at pp. 1003-1005, 1010.) The court rejected the

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