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As a subscriber you can listen to articles at work, in the car, or while you work out. Subscribe NowThe 7th Circuit Court of Appeals affirmed a district court’s ruling sentencing an Evansville man to 35 years in prison for distribution of a controlled substance resulting in serious bodily injury.
In affirming the district court’s opinion, the appeals court confirmed that the government proved beyond a reasonable doubt that, had the appellant not given the victim heroin, she likely would not have overdosed.
The case was argued in front of circuit court judges Diane Sykes, David Hamilton and Doris Pryor in January 2025 and decided on Aug. 11, 2026.
Before the court was the argument of whether prosecutors presented enough evidence to support the jury’s verdict that defendant and appellant Johntavis Matlock’s heroin was a “but-for” cause of the victim’s overdose. In other words, the government had to prove beyond a reasonable doubt that “but for” the heroin, Wiley’s overdose would not have happened.
In June 2021, a federal grand jury indicted Matlock, charging him with distributing a controlled substance resulting in serious bodily injury, distributing a controlled substance that resulted in death, possession of a firearm as a felon and possession of a controlled substance.
The charges followed the death of Matlock’s friend Lindsey Wiley, who died in February 2021 from a drug overdose, according to court documents.
Prior to her death, Wiley had purchased heroin from Matlock in December 2020. Shortly after purchasing and ingesting the heroin, Wiley overdosed but regained consciousness after paramedics administered Narcan.
When police responded to the 911 call about Wiley’s overdose, officers observed several items in Wiley’s bedroom showing evidence of drug use and the fact Wiley had Type 1 diabetes that was poorly managed at times, according to court documents.
Wiley and Matlock continued to communicate after Wiley’s overdose and in February 2021, Matlock offered her what he had left of a new batch of heroin he had, court documents state. Wiley originally turned down Matlock’s offer but later asked to purchase the drug. The morning after Wiley appeared to have purchased heroin from Matlock, she was found dead from an overdose.
During his trial, Matlock’s attorneys contended the government’s evidence was insufficient in meeting the standard for “but-for” causation in regards to the “serious bodily injury” and “death” drug distribution charges.
They alleged that Wiley’s death could have been caused by other substances, citing the paraphernalia in her bedroom.
Matlock filed a motion for acquittal which the district court denied. He was acquitted of the drug distribution resulting in death charge, but appealed the bodily injury charge.
The 7th Circuit upheld the District Court’s decision based on “but-for” causation, showing through case law that Matlock’s heroin did not have to be the definitive cause of Wiley’s overdose to qualify as “but-for” causation.
“The presence of ‘other substances in [a victim’s] bloodstream’ satisfies the but-for causation standard when the drug the defendant provided “pushed [a victim] over the edge,” the 7th Circuit wrote in its opinion.
Case: United States v. Matlock, No. 23-3374
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