Commonwealth v. Carlson

Carol Suprenant suffered from chronic obstructive pulmonary disease and relied on an oxygen tank to assist her with breathing. Suprenant’s disease was degenerative, and Suprenant had informed relatives that she at no point wanted to be kept alive using a ventilator. One day, Suprenant and her husband were driving to a barbeque. Carlson (defendant) ran a stop sign and collided with the passenger side of Suprenant’s vehicle. Suprenant, who was sitting in the passenger seat, sustained multiple chest-wall fractures. While in intensive care, Suprenant was placed on a ventilator. The morning after the accident, Suprenant was moved from intensive care, and the ventilator was removed. Over the next few days, Suprenant struggled to breathe, and doctors encouraged her to go back on a ventilator. Suprenant resisted, but eventually relented after encouragement from multiple family members and doctors. The next day, however, Suprenant’s kidneys began to fail. Suprenant decided to be taken off the ventilator rather than persisting with a ventilator and dialysis to see if her condition would improve. After discussions with doctors, Suprenant was aware that this decision would likely result in death. Suprenant was also aware that more time on the ventilator might allow her to survive, albeit with a likely reduction in breathing capacity. Suprenant died a few hours after being removed from the ventilator. Carlson was convicted of motor-vehicle homicide by negligent operation. Carlson appealed the decision on the ground that the accident was not the cause of Suprenant’s death.