Fuller v. Preis
363 N.Y.S.2d 568, 322 N.E.2d 263, 35 N.Y.2d 425 (1974)
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Rule of Law:
A negligent tortfeasor may be held liable for the subsequent suicide of their victim if the negligence caused a mental condition, such as a derangement or an irresistible impulse, that was a substantial cause of the suicide. The act of suicide is not, as a matter of law, a superseding cause that automatically breaks the chain of causation.
Facts:
- On December 2, 1966, Dr. Lewis, a surgeon, was in a car accident caused by the defendants, during which he struck his head against his car's frame.
- Initially believing he was uninjured, he soon began experiencing seizures and was diagnosed with a subdural contusion, cerebral concussion, and post-traumatic focal seizures.
- Over the next seven months, Dr. Lewis's condition deteriorated; he suffered at least 38 seizures, became depressed and irritable, and was forced to give up his surgical practice.
- His wife was suffering from 'nervous exhaustion' and his mother had recently been diagnosed with cancer.
- On July 9, 1967, after experiencing three seizures, Dr. Lewis locked himself in a bathroom, was heard muttering 'I must do it', and fatally shot himself in the head.
- Two suicide notes were found. One professed love for his wife, while the other gave financial instructions and stated he was 'perfectly sane' and that the note must be kept secret to not jeopardize the 'outcome of the case'.
Procedural Posture:
- Plaintiff executor filed a wrongful death action against the defendants in a state trial court.
- A jury returned a verdict in favor of the plaintiff for $200,000.
- Defendants, as appellants, appealed the judgment to the Appellate Division, an intermediate appellate court.
- The Appellate Division set aside the jury's verdict and dismissed the complaint.
- Plaintiff executor, as appellant, appealed the dismissal to the New York Court of Appeals, the state's highest court.
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Issue:
Does evidence that a tortfeasor's negligence caused organic brain damage, followed by seizures and depression, which culminated in the victim's suicide, present a sufficient question of fact for a jury to determine whether the negligence was the proximate cause of the death?
Opinions:
Majority - Chief Judge Breitel
Yes. Evidence that a defendant's negligence caused a mental derangement that resulted in an irresistible impulse to commit suicide is sufficient to create a question of fact for the jury regarding proximate cause. The court reasoned that neither public policy nor precedent bars recovery for the suicide of a tortiously injured person. Suicide is not a superseding cause as a matter of law; rather, the central question is whether the victim's act was an involuntary consequence of the injury. Despite evidence suggesting rational planning, such as the suicide notes, there was sufficient expert testimony connecting the accident to organic brain damage, postconvulsive psychosis, and an inability to control his conduct. This created a classic factual dispute for the jury to resolve regarding whether the brain damage substantially contributed to his death, even if other life stressors were also present.
Analysis:
This decision solidifies the principle that suicide does not automatically sever the chain of proximate cause in a negligence action. It affirms that the critical inquiry is the victim's state of mind and whether the defendant's wrongful act caused a mental condition that led to an 'irresistible impulse' to self-destruct. By deferring to the jury's role as fact-finder in weighing conflicting evidence (expert testimony vs. suicide notes), the case sets a precedent that makes it more difficult for defendants to obtain dismissal as a matter of law in similar cases. The ruling aligns tort law with a more modern understanding of mental illness, recognizing that a person can act with knowledge and intent while still being driven by an uncontrollable, tortiously-caused impulse.
