State v. Pelham

Brief Fact Summary.

Pelham appealed a conviction of second-degree vehicular homicide claiming that taking the victim off of life support absolves Pelham of responsibility for the murder.

Synopsis of Rule of Law.

A defendant is the legal cause of an event if no intervening event changes the chain of causation and his actions directly causes the event.

Facts.

Pelham put Patrick into the hospital due to a car accident. After the accident, Patrick’s family decided to take him off of life support. Pelham was charged with first-degree aggravated manslaughter and the jury ultimately convicted Pelham of second-degree vehicular homicide. Pelham appealed.

Issue.

Whether the voluntary removal of a victim’s life support is absolves the individual who put the victim in the hospital of responsibility?

Held.

No. Pelham’s conviction is upheld because Patrick would not have died if Pelham had not driven drunk and caused an accident.

Dissent.

(Albin, J.) Depriving the jury of the opportunity to decide whether removing a victim from life support is a sufficient intervening cause goes against the purpose of the judicial system.

Discussion.

A defendant is absolved of responsibility if an intervening cause breaks the chain of causation. If a person car crashes into a person, but the car’s breaks fail, that is a sufficient intervening cause that absolves the driver of guilt.