Commonwealth v. Carlson

Brief Fact Summary.

Suprenant was involved in a car accident when Defendant ran a red light and struck the passenger side of the vehicle she was situated in. Suprenant sustained multiple chest-wall factures, and Suprenant was taken to an intensive care unit and placed on a ventilator. Subsequently, Suprenant decided she did not want to be on the ventilator, knowing removal of the ventilator would likely cause her death. Suprenant was taken off the ventilator, and she died a couple hours later. Defendant was charged and convicted of motor-vehicle homicide by negligent operation. Defendant appealed.

Synopsis of Rule of Law.

One’s conduct is the proximate cause of an individual’s death when the former’s conducts is part of a natural and continuous sequence of events, and the latter’s death would not have occurred without the former’s conduct.

Facts.

Carol Suprenant was diagnosed with chronic obstructive pulmonary disease and depended heavily on an oxygen tank to aid her in breathing. Suprenant’s disease was worsening. Thus, Suprenant told her relatives that she did not want to be kept alive with a ventilator. Subsequently, Suprenant and her husband were on their way to a barbeque when Carlson, Defendant, drove through a stop sign, causing Defendant’s vehicle to strike with the passenger side of Suprenant’s vehicle. At that time, Suprenant was sitting in the passenger seat of the vehicle; therefore, she was injured and endured multiple chest-wall fractures. On the same day, Suprenant was taken to an intensive care unit and placed on a ventilator. The following morning, Suprenant was removed from the intensive care unit, and she was removed from the ventilator. Thereafter, Suprenant had trouble, and doctors urged her to begin using the ventilator again. Nevertheless, Suprenant opposed the use of the ventilator at first, however, after her family members and doctors continued to urge her to use the ventilator, she began to use it again. Nonetheless, the subsequent day, Suprenant’s kidneys started to fail, causing Suprenant to choose to be removed from the ventilator. Suprenant refused to continue being on the ventilator and dialysis to evaluate whether her condition could improve. The doctors discussed Suprenant condition with her, making Suprenent aware that her refusal to be on the ventilator and dialysis would likely result in her death. Likewise, Suprenant knew that the more she used the ventilator the more likely she would survive her condition, even with a reduced breathing capacity. Moreover, Suprenant died a few hours after she was removed from the ventilator. Later, Defendant was charged and convicted of motor-vehicle homicide by negligent operation, and Defendant appealed the decision alleging he did not cause Suprenant’s death.  

Issue.

Whether one’s conduct is the proximate cause of an individual’s death when the former’s conducts is part of a natural and continuous sequence of events, and the latter’s death would not have occurred without the former’s conduct.

Held.

Yes, one’s conduct is the proximate cause of an individual’s death when the former’s conducts is part of a natural and continuous sequence of events, and the latter’s death would not have occurred without the former’s conduct.

Discussion.

One’s conduct is the proximate cause of an individual’s death when the former’s conducts is part of a natural and continuous sequence of events, and the latter’s death would not have occurred without the former’s conduct. Nevertheless, if a third party intervenes and makes an additional act in the chain of causation that was not reasonably foreseeable, then the former may not be liable. The jury is responsible for determining if a third party’s actions were reasonably foreseeable. Moreover, the Prosecution must prove that the defendant operated a vehicle on a public road in a negligent manner that threatens the public’s safety and the lives of others, which causes the death of another individual.  This case rests on the causation element. The court notes that Defendant’s actions certainly instigated the chain of events that led to Suprenant’s death. In he chain of events, Suprenant had to pick from two extremes, an invasive life-support measure, a ventilator and dialysis treatment, and comfort-only measures. The invasive measure could have not only saved Suprenant’s life, but it could have also led Suprenant to a life of dependency on the ventilator. Therefore, based on the totality of the circumstances, the jury properly concluded that Suprenant was entitled to chose which measure she wanted to endure, including the decision to reject treatment. Further, Surprenant’s decision was a reasonably foreseeable action in the chain of events, which does not break causation. Thus, Defendant is liable for Suprenant’s death. Likewise, Defendant’s assertion that Suprenant was not, previous to the accident, an ordinary healthy individual, should be considered. This assertion is incorrect because the basic tort principle, which indicates, “you take your victim as you find him” also applies to negligent criminal conduct. Thus, Defendant’s conviction is affirmed.