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State v. Pelham

Supreme Court of New Jersey
824 A.2d 1082 (2003)


Facts

Pelham (defendant) was involved in a car accident with Patrick, who was paralyzed in the accident. Pelham was drunk when the accident occurred, having a BAC of .22. Patrick’s condition worsened in the hospital, and he was placed on a respirator due to his inability to breathe on his own. After months of his condition worsening, Patrick’s family decided to take him off the respirator, and Patrick died two hours afterwards. Pelham was charged with first-degree aggravated manslaughter. At trial, the judge instructed the jury to convict Pelham if the accident caused Patrick’s injuries and subsequent death. In these instructions, the judge stated that the removal of life support was not a sufficient intervening cause to break the chain of causation between Pelham’s actions and Patrick’s death. The jury acquitted Pelham of aggravated manslaughter, but convicted him of second-degree vehicular homicide, a lesser offense. Pelham appeals his conviction, claiming that the removal of life support could have been an intervening cause that broke the chain of causation, and that the jury instruction stating otherwise was incorrect, requiring a new trial.

Rule of Law

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Issue

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Holding and Reasoning (LaVecchia, J.)

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  • A "yes" or "no" answer to the question framed in the issue section;
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Dissent (Albin, J.)

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