Commonwealth v. Carlson

Rule of Law:

A competent victim's informed decision to refuse potentially life-saving medical treatment is not a legally superseding cause of death that relieves a defendant from criminal liability for motor vehicle homicide. The defendant's antecedent negligence remains the proximate cause of death if the victim's refusal of treatment was a reasonably foreseeable consequence of the injuries inflicted.

Facts:

• The defendant negligently operated her automobile, running a stop sign and striking a car in which Carol Suprenant was a passenger.
• The collision caused Suprenant, who suffered from a pre-existing severe lung condition (COPD), to sustain multiple chest wall fractures and a lung contusion.
• Suprenant's injuries exacerbated her COPD, compromising her ability to breathe and requiring her to be placed on a mechanical ventilator.
• After a few days, Suprenant's condition worsened, and doctors advised she needed to be reintubated.
• Suprenant had repeatedly expressed a desire never to be kept alive by a ventilator.
• After being reintubated temporarily, her kidneys began to fail, and she was informed she would also need dialysis.
• Understanding that her decision would likely lead to her death, Suprenant adamantly and competently decided to be removed from the ventilator.
• A few hours after the ventilator was removed at her request, Suprenant died of respiratory failure.

Procedural Posture:

• The defendant was charged by complaint with motor vehicle homicide by negligent operation in the East Brookfield Division of the District Court Department.
• At the close of the Commonwealth's case, the defendant moved for a required finding of not guilty, which the trial judge denied.
• The defendant renewed the motion at the close of all evidence, and the trial judge denied it again.
• A jury convicted the defendant on the charge.
• The defendant appealed the conviction, and the Supreme Judicial Court of Massachusetts transferred the case on its own motion.