People v. Snyder
937 N.Y.2d 429, 91 A.D.3d 1206 (2012)
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Rule of Law:
A prolonged, brutal, and ultimately fatal course of conduct against a particularly vulnerable victim, even if driven by a conscious objective to harm rather than to kill, can satisfy the mens rea of depraved indifference if the defendant's actions reflect an utter disregard for the value of human life.
Facts:
- Starting in 1992, the defendant's infant son began experiencing numerous, medically unexplainable episodes of breathing difficulty.
- Each of the son's episodes occurred when the defendant was the only adult present, and the episodes ceased when a doctor ordered that she not be left alone with the child in the hospital.
- The defendant's daughter, born subsequently, suffered from identical, medically unexplainable breathing problems, with one test indicating her apnea was caused by an airway blockage.
- The defendant successfully applied for and received Supplemental Security Income (SSI) disability benefits on behalf of both children, citing their breathing problems.
- The defendant confessed to a fellow inmate that she had been inducing the breathing problems in her children to obtain disability benefits and had used a pillow on her daughter on the day she died.
- In January 1996, the defendant's daughter was found not breathing and ice cold by a parent monitor; the defendant had not called for help and remained calm and detached while others rendered aid and at the hospital.
- The daughter died a few days later from a lack of oxygen and inadequate blood flow to the brain.
- The defendant told a mobile home salesperson that her daughter's SSI benefits were her main source of income and that she expected them to continue for the child's entire life.
Procedural Posture:
- The defendant was prosecuted by the People of New York in Franklin County Court, a trial-level court.
- A jury convicted the defendant of murder in the second degree, assault in the first degree, and reckless endangerment in the first degree.
- The trial court entered a judgment of conviction in 2001, from which the defendant filed a timely appeal.
- The defendant later filed a motion pursuant to CPL 440.10 to vacate the judgment on the ground of ineffective assistance of counsel.
- The trial court denied the defendant's CPL 440.10 motion in 2005, and the defendant appealed that denial.
- The defendant's direct appeal and the appeal from the denial of her CPL 440.10 motion were consolidated before the New York Supreme Court, Appellate Division, Third Department.
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Issue:
Does a defendant's prolonged course of conduct of repeatedly suffocating her children for the purpose of obtaining financial benefits constitute legally sufficient evidence to establish the mens rea of depraved indifference to human life for convictions of murder and assault?
Opinions:
Majority - Garry, J.
Yes. A defendant's prolonged and brutal course of conduct against vulnerable victims, even when not intended to kill, is legally sufficient to establish the mens rea of depraved indifference. The evidence showed the defendant repeatedly suffocated her two helpless children and subjected them to unnecessary medical procedures for financial gain. This course of conduct reflects wanton cruelty and an utter disregard for the value of human life, which satisfies the mens rea element for depraved indifference under the modern standard established in People v. Feingold. The defendant's desire for her children to live solely so she could continue to brutalize them for financial gain is the epitome of depraved indifference, not a mitigating factor showing concern for their lives.
Concurring - Stein, J.
Yes. The concurring opinion agrees that the convictions should be affirmed but argues that the legal sufficiency of the evidence should have been reviewed under the law as it existed at the time of trial, not the newer standard from People v. Feingold. Because the defendant did not object to the jury charge, the older, objective standard for depraved indifference should apply, and under that standard, the evidence was legally sufficient. The concurrence further posits that if the new Feingold standard were applied, the defendant would be entitled to a new trial because the original jury was never instructed on the mens rea element, and an appellate court cannot substitute its own finding for that of a jury.
Analysis:
This case is significant for its application of the modern, narrowed definition of depraved indifference as a subjective mens rea element to a scenario of prolonged child abuse for financial gain (often associated with Munchausen syndrome by proxy). The court clarifies that an actor's conscious objective to harm, rather than kill, does not preclude a finding of depraved indifference. By focusing on the defendant's "utter disregard for the value of human life," the decision reinforces that a prolonged, brutal course of conduct against a vulnerable victim is a primary category of conduct that satisfies the heightened mens rea requirement post-Feingold, distinguishing it from intentional murder.
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