63 N.Y.2d 341
SYNOPSIS: Defendants sought review of the judgments of the Appellate Division of the Supreme Court in the Second Judicial Department (New York), which affirmed the trial court's verdicts convicting them of manslaughter, on the ground 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.
-The homicide victims in both cases were shot in the head.
-After medical tests indicated that each victim's entire brain had irreversibly ceased to function and they were pronounced dead, some of their organs were removed for transplantation before 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.
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.
OUTCOME: The court affirmed the order of the appellate division in each case.
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