State v. Pelham
824 A.2d 1082 (2003)
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Rule of Law:
A victim's decision to terminate life-sustaining medical treatment is a foreseeable consequence of a defendant's criminal act and does not constitute an independent intervening cause that breaks the chain of causation for criminal homicide liability.
Facts:
- On December 29, 1995, Sonney Pelham, while driving with a blood alcohol content estimated between .19 and .22, struck the rear of a car driven by William Patrick.
- The collision inflicted catastrophic injuries on Patrick, including a spinal fracture that resulted in paralysis from the chest down, a 'flailed chest,' a punctured lung, and a head injury, rendering him unable to breathe on his own.
- Patrick was immediately placed on a ventilator and required extensive life-sustaining medical intervention for the next five months.
- During his hospitalization, Patrick suffered from numerous severe complications, including organ failure, sepsis, recurring pneumonia, and significant brain injury.
- Patrick had previously expressed to his family a desire not to be kept alive on life support.
- Acting in accordance with Patrick's known wishes, his family decided to have the ventilator removed on May 30, 1996.
- Patrick died within hours of the ventilator's removal.
- The medical examiner determined the cause of death to be sepsis and bronchopneumonia resulting from the multiple injuries sustained in the car accident.
Procedural Posture:
- Sonney Pelham was indicted for first-degree aggravated manslaughter in the trial court (Law Division).
- Pelham filed a pre-trial motion to dismiss the indictment, arguing the victim's removal from a ventilator was an independent intervening cause of death; the trial court denied the motion.
- A jury acquitted Pelham of aggravated manslaughter but convicted him of the lesser-included offense of second-degree death by auto (vehicular homicide).
- Pelham, as appellant, appealed to the intermediate appellate court (Appellate Division), which reversed the conviction and remanded for a new trial, finding the jury instruction on causation was erroneous.
- The State, as petitioner, was granted certification to appeal to the Supreme Court of New Jersey, the state's highest court.
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Issue:
Does a victim's voluntary removal from life support constitute an independent intervening cause sufficient to break the chain of causation and relieve a defendant of criminal liability for the victim's resulting death?
Opinions:
Majority - LaVecchia, J.
No, a victim's voluntary removal from life support does not constitute an independent intervening cause sufficient to relieve a defendant of criminal liability. New Jersey public policy, established through case law like In re Quinlan and statutory law like the Advance Directives for Health Care Act, firmly recognizes an individual's right to refuse life-sustaining treatment. The exercise of this right is a foreseeable event, not an extraordinary or abnormal occurrence that can break the chain of causation. The court reasoned that the discontinuance of life-support measures merely allows the patient's underlying injury or illness—inflicted by the defendant—to take its natural and inevitable course. Therefore, removal of life support is not a legally cognizable cause of death. A trial court may properly instruct the jury, as a matter of law, that it cannot consider the victim's removal from life support as an intervening cause of death if the defendant's actions set in motion the need for that life support.
Dissenting - Albin, J.
The victim's voluntary removal from life support should be considered by a jury as a potential independent intervening cause. The New Jersey Code of Criminal Justice (N.J.S.A. 2C:2-3c) explicitly requires the jury to determine whether a death was 'too remote ... or dependent on another's volitional act to have a just bearing on the actor's liability.' A victim's decision to terminate medical treatment is a 'volitional act' that falls squarely within this statutory language. By creating an inflexible, per se rule, the majority usurps the jury's fundamental role in deciding the essential element of causation. The trial court's instruction amounted to a directed verdict on causation, violating the defendant's constitutional right to a trial by jury, which should be trusted to make a just determination based on the unique facts of each case.
Analysis:
This decision establishes a bright-line rule in New Jersey that forecloses a common defense argument in homicide cases where victims are removed from life support. By declaring the removal of life support to be a foreseeable act as a matter of law, the Court prioritizes the victim's well-established right to self-determination in medical care. This precedent prevents defendants from leveraging a victim's choice to die with dignity into a defense against criminal liability, thereby ensuring that the legal cause of death is attributed to the initial criminal act that necessitated the life support. The ruling simplifies the causation analysis for future juries but, as the dissent argues, removes from their consideration a factor ('another's volitional act') explicitly mentioned in the state's causation statute.
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