State v. Fierro
1979 Ariz. LEXIS 356, 124 Ariz. 182, 603 P.2d 74 (1979)
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Rule of Law:
The act of removing life support systems from a victim who is medically determined to be 'brain dead' is not an intervening cause of death that relieves the initial assailant of criminal liability for murder. A determination of death may be based on the irreversible cessation of all brain function, a standard adopted in addition to the common law definition of death.
Facts:
- On August 18, 1977, David Fierro was instructed by a member of the 'Mexican Mafia' to kill Victor Corella.
- Fierro located Corella, who was a passenger in a car driven by Ray Montez.
- Fierro told Montez of his intention, asked him to drive away, and then shot Corella once in the chest and four times in the head.
- Corella was taken to Maricopa County Hospital, where he was placed on life support systems due to severe bleeding.
- A neurological examination revealed that Corella had suffered 'brain death.'
- After follow-up studies over three days confirmed the irreversible cessation of brain function, doctors terminated the life support systems.
- Corella was pronounced dead on August 22, 1977, four days after the shooting.
Procedural Posture:
- David Madrid Fierro was charged with first-degree murder.
- The case was tried before a jury in the Maricopa County Superior Court, which is the trial court of first instance.
- The jury returned a verdict of guilty.
- The trial court entered a judgment of guilt and sentenced Fierro to life imprisonment.
- Fierro, as the appellant, filed a direct appeal of his conviction and sentence to the Supreme Court of Arizona.
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Issue:
Does the act of removing a brain-dead victim from life support systems constitute a superseding, intervening cause of death sufficient to relieve the initial assailant of criminal liability for murder?
Opinions:
Majority - Cameron, Chief Justice
No. The removal of life support systems from a brain-dead victim is not a legally sufficient intervening cause of death that breaks the chain of causation initiated by the defendant's criminal act. The court reasoned that a defendant is guilty of homicide if the injury they inflict contributes to the death, and the fact that other causes contribute does not relieve the actor of responsibility unless those other causes are the proximate cause of death. Here, the gunshot wounds were the proximate cause, and the removal of life support merely allowed the natural progression of the victim's condition to death. The court further held that the victim was legally dead before the life support was terminated, adopting the 'brain death' standard—the irreversible cessation of all brain function—as a valid legal definition of death in Arizona, alongside the traditional common law definition based on circulatory and respiratory cessation. Because expert testimony confirmed Corella had suffered irreversible brain death, he was legally dead before the support systems were withdrawn, and Fierro's actions were the direct cause of that death.
Analysis:
This case is significant for modernizing the legal definition of death in Arizona by formally recognizing 'brain death' as a valid standard. By doing so, the court aligned legal principles with contemporary medical advancements, ensuring that criminal defendants cannot escape homicide charges by blaming medical professionals for ceasing life support on a victim whose brain function is irreversibly lost due to the defendant's actions. This decision provides crucial legal clarity for causation in homicide cases involving life support and has implications for related areas of law, such as organ transplantation. It establishes a clear precedent that the original fatal injury, not the subsequent termination of futile medical care, is the proximate cause of death.
