People v. Eulo

63 N.Y.2d 341, 482 N.Y.S.2d 436, 472 N.E.2d 286 (1984)



When the legislature has failed to assign definition to a statutory term, the courts will generally construe that term according to its ordinary and accepted meaning as it was understood at the time. If the term at issue has been judicially defined prior to its use in a statute, however, that definition will be assigned to the term, absent contrary indications. In every case, of course, the term must be read in accordance with the apparent purpose of the statute in which it is found.


Both victims were shot in the head, in unrelated incidents. Once at the hospital, they were placed on mechanical respirators to maintain breathing and medication was administered to sustain heartbeat and stabilize blood pressure. After medical tests were undertaken to evaluate damage done to the brain, it was determined that each victim's entire brain had irreversibly ceased to function and they were pronounced dead. Some of their organs were removed for transplantation, the respirators were disconnected, and the victims' breathing and heartbeat stopped.The New York penal code did not define "death" and prior judicial definitions followed the traditional criteria of irreversible cardiorespiratory repose. Cases for murder were filed with the court and after jury trials, both defendants were convicted of manslaughter. On appeal, the Appellate Division of the Supreme Court in the Second Judicial Department (New York) affirmed the decision. The case was appealed to the Court of Appeals of New York with the defendants contending that their conduct did not cause the victim's death and that the respective trial judges failed to adequately instruct the juries as to what constituted a person's death, the time at which criminal liability for a homicide attached.


Was the jury instructed properly at trial?




The court held that recognition of brain-based criteria for determining death was not unfaithful to prior judicial definitions of "death." When respiratory and circulatory functions were maintained by mechanical means, death was properly deemed to occur when it was determined that the entire brain's function had irreversibly ceased. The court found that the juries were adequately instructed on their obligation to determine the fact and causation of death. The court concluded that there was sufficient evidence for a rational juror to have concluded beyond a reasonable doubt that each defendant's conduct caused the victim's death and that the medical procedures were not superseding causes of death.

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