In the Matter of Z.A.K., 189 N.C. App. 354 (2008)

The trial court did not err by denying the juvenile’s motion to dismiss the manslaughter petition for insufficient evidence. The juvenile argued the state failed to establish proximate cause where the victim died from a drug overdose after ingesting various drugs because it failed to prove that the Ecstacy, the only drug he provided, caused the victim’s death. Rather than address that issue, the Court of Appeals concluded that the juvenile’s actions after the victim became ill constituted “culpable negligence,” which is sufficient to support an adjudication for involuntary manslaughter.