Commonwealth v. Konz
450 A.2d 638, 1982 Pa. LEXIS 567, 498 Pa. 639 (1982)
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Rule of Law:
A spouse does not have a legal duty to seek medical assistance for their competent adult spouse who has consciously and rationally chosen to refuse such aid, even if that refusal leads to death.
Facts:
- Reverend David G. Konz, a diabetic for 17 years who self-administered insulin daily, publicly proclaimed he would stop taking insulin based on his religious belief that God would heal him.
- Konz and Stephen R. C. Erikson formed a prayer pact to help Konz resist the temptation to take insulin.
- When Konz's condition worsened and he sought insulin, his wife, Dorothy A. Konz, and Erikson prevented him by hiding the medicine, blocking his path, and disabling a telephone during a struggle.
- Immediately following this confrontation, Reverend Konz stated to his aunt that "It's all settled now" and told his daughter "Everything is fine."
- Later that day, Reverend Konz drove his wife to a hospital facility where insulin was available; despite appearing fatigued, he conversed rationally and did not request any medical assistance.
- Over the next 36 hours, Reverend Konz's condition deteriorated, and he experienced vomiting and restlessness.
- On Sunday afternoon, he recognized visitors' voices and called out to them from his room.
- On Monday morning, Reverend Konz died of diabetic ketoacidosis.
Procedural Posture:
- Dorothy A. Konz and Stephen R. C. Erikson were charged with involuntary manslaughter.
- Following a trial in the Court of Common Pleas of the Thirty-First Judicial District, a jury found both defendants guilty.
- The trial court granted the defendants' post-verdict Motion in Arrest of Judgment, setting aside the guilty verdicts.
- The Commonwealth, as appellee, appealed the trial court's order to the Superior Court.
- The Superior Court reversed the trial court's order, thereby reinstating the jury's guilty verdicts.
- The defendants, Dorothy A. Konz and Stephen R. C. Erikson, as appellants, appealed to the Supreme Court of Pennsylvania.
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Issue:
Does a spouse have a legal duty, the breach of which could lead to criminal liability for involuntary manslaughter, to seek medical assistance for their competent adult spouse who has consciously chosen to refuse such aid?
Opinions:
Majority - Flaherty, J.
No. A spouse does not have a legal duty to seek medical assistance for a competent adult spouse who has consciously chosen to refuse such aid. The court rejected the idea of an unrestricted spousal duty to summon medical aid, distinguishing it from the parent-child relationship where a child is inherently dependent and incapable of seeking help. Imposing such a duty on a spouse would force them to override the competent, expressed preferences of their partner. In this case, after the initial confrontation, Reverend Konz had numerous opportunities to seek medical assistance—from his aunt, at the hospital facility, or from visitors—but he consciously chose not to. His behavior indicated that he was rational, aware of his condition, and had made a firm, competent decision to forgo treatment, thereby relieving Mrs. Konz of any legal duty to act against his wishes.
Dissenting - McDermott, J.
Yes. The defendants' affirmative actions created a situation where criminal liability for involuntary manslaughter was appropriate, and the jury's verdict should be upheld. The dissent argues that the majority improperly reweighed the evidence and disregarded the principle of viewing facts in the light most favorable to the verdict winner. The evidence showed that the appellants did not merely fail to act; they actively prevented Reverend Konz from obtaining life-sustaining insulin by hiding it, physically restraining him, and disabling a phone. The jury was specifically instructed that if Reverend Konz competently refused treatment, they must find the defendants not guilty. By returning a guilty verdict, the jury explicitly rejected the majority's factual conclusion, and the court should not substitute its own judgment for that of the fact-finder.
Concurring - Nix, J.
No. The record does not support criminal liability under either a theory of affirmative acts or a failure to act. The affirmative acts on Saturday were not the legal cause of death because Reverend Konz's subsequent, conscious decision to continue forgoing insulin acted as an intervening, superseding cause. Regarding a duty to act (omission), Mrs. Konz lacked the requisite mental state (mens rea) for criminal liability. Since she shared her husband's religious views and had no superior medical knowledge, she did not possess the necessary awareness of the life-threatening risk required to establish a criminal failure to act.
Analysis:
This decision significantly clarifies the legal duty to act within a spousal relationship, establishing that this duty is not absolute. The court grounds its holding in the principle of personal autonomy, ruling that a spouse is not legally obligated to override the competent, conscious medical decisions of their partner. This precedent protects individuals from criminal liability for respecting a spouse's wishes, even if those wishes result in death, and sets a high bar for imposing criminal liability for omissions in the context of competent adults.
