State v. Pelham
Supreme Court of New Jersey
824 A.2d 1082 (2003)
Driving with a BAC of .22, Pelham (defendant) caused a car accident that paralyzed Patrick, who was placed on a respirator and, after months of deteriorating condition, was taken off life support by his family and died two hours later. Charged with first-degree aggravated manslaughter, Pelham was acquitted of that top charge but convicted of the lesser offense of second-degree vehicular homicide after the trial judge instructed the jury that removing life support was not a legally sufficient intervening cause to break the causal chain between Pelham's driving and Patrick's death. Pelham appealed, arguing the jury should have been allowed to consider whether the life-support removal was an intervening cause.
Whether the voluntary removal of a victim's life support is a sufficient intervening event to absolve a defendant who caused the circumstances ultimately leading to the victim's death.