State v. Pelham

824 A.2d 1082 · Supreme Court of New Jersey · 2003

Facts

On December 29, 1995, defendant Sonney Pelham, driving while intoxicated, struck William Patrick's car from behind on Route 1 in South Brunswick. Patrick, 66, sustained catastrophic injuries including paralysis, a flailed chest, and head trauma, necessitating life support. Despite extensive medical care and transfer to a rehabilitation facility, Patrick's condition deteriorated, and he developed numerous infections. Aware of his physical and cognitive disabilities, Patrick had previously expressed a wish not to be kept alive on life support. On May 30, 1996, his family, acting on his wishes, removed the ventilator, and he died within two hours. The medical examiner attributed his death to complications from the accident injuries.

Issue

Can a victim's voluntary decision to be removed from life support constitute an independent intervening cause that breaks the chain of causation, thereby lessening a criminal defendant's liability for death? Was the trial court's instruction to the jury, stating that such removal is not an intervening cause, permissible?

Holding

The court reversed the Appellate Division, holding that a victim's decision to terminate life support cannot, as a matter of law, be considered an independent intervening cause capable of breaking the chain of causation for criminal liability. The trial court's instruction to the jury on this point was not error. The judgment of conviction was reinstated.

Rule

A victim's determination to be removed from life support is a foreseeable event that does not remove or lessen criminal responsibility for death. The removal of life support, in conformity with a victim's expressed wishes, is not a legally cognizable independent intervening cause. This is because the exercise of the right to refuse life-sustaining treatment does not break, in an unexpected or extraordinary way, the chain of causation initiated by the defendant's actions that led to the need for life support. Therefore, a defendant's criminal liability may not be lessened by such a subsequent decision.

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