People v. Matos, 19 N.Y.3d 471 (2012)
To be convicted of depraved indifference murder, the defendant must have exhibited an utter disregard for the value of human life, demonstrating a willingness to act not because one intends harm, but because one simply doesn’t care whether grievous harm results or not.
Summary
Matos was convicted of depraved indifference murder of her 23-month-old son after he died from severe abuse inflicted by her partner. She delayed seeking medical attention for approximately seven hours, during which time she attempted to treat him with home remedies and conceal evidence of the abuse. The New York Court of Appeals reversed the conviction, holding that the evidence was insufficient to prove that Matos possessed the culpable mental state of depraved indifference because she took some actions to help the child, albeit inadequately, and eventually called for help. The Court emphasized that depraved indifference requires an utter disregard for human life, which was not demonstrated here.
Facts
Carmen Molina severely beat Matos’s 23-month-old son, breaking his leg and ribs, and injuring his liver and lungs, causing severe internal bleeding.
When Matos returned home, Molina told her the child was injured.
Matos knew her son was “hurt bad” but claimed she didn’t think he was seriously injured or would die.
Instead of calling for help, Matos bought ACE bandages at Molina’s urging and created a makeshift splint.
She gave her son ibuprofen and put him to bed.
Approximately seven hours later, after finding the child bleeding, Matos called the police from a neighbor’s phone.
The child was pronounced dead at the hospital.
Matos initially gave false accounts to the police before admitting Molina had beaten the child and that she helped hide evidence.
Procedural History
Matos and Molina were indicted on murder and child endangerment charges.
Molina pleaded guilty to second-degree murder.
Matos was tried before a jury and acquitted of traditional depraved indifference murder but convicted of depraved indifference murder of a child and child endangerment.
The Appellate Division affirmed the conviction.
The New York Court of Appeals granted leave to appeal.
Issue(s)
Whether the evidence presented at trial was sufficient to prove that Matos possessed the culpable mental state of depraved indifference to human life to warrant a conviction for depraved indifference murder of a child under Penal Law § 125.25(4).
Holding
No, because the evidence did not demonstrate that Matos acted with an utter disregard for her son’s life. Her actions, while insufficient, indicated some concern for his well-being, negating the required mental state for depraved indifference murder.
Court’s Reasoning
The Court emphasized that depraved indifference requires an utter disregard for human life, a willingness to act not because one intends harm, but because one simply doesn’t care whether grievous harm results or not, quoting People v. Feingold, 7 N.Y.3d 288 (2006).
The Court distinguished this case from situations where the defendant’s actions demonstrated a complete lack of concern for the victim’s life.
While Matos’s behavior was egregious and fell far short of expected parental conduct, it did not rise to the level of “wickedness, evil or inhumanity” required for depraved indifference murder, quoting People v. Suarez, 6 N.Y.3d 202 (2005).
The Court noted that Matos’s actions, such as splinting her son’s leg and giving him ibuprofen, however inadequate, indicated some level of care, contrasting this with a complete failure to act.
The Court stated that while the evidence clearly shows that defendant “cared much too little about her child’s safety, it cannot support a finding that she did not care at all”, quoting People v. Lewie, 17 N.Y.3d 348 (2011).
The Court also clarified that attempting to conceal the crime does not prove indifference to it, quoting People v. Lewie, 17 N.Y.3d 348 (2011).
The Court acknowledged that the legislative intent behind Penal Law § 125.25(4) when first enacted was to define the factual setting in which the risk-creating conduct occurred, rather than to define “depraved indifference” as a culpable mental state.
However, the Court noted that in the wake of People v. Feingold, 7 N.Y.3d 288 (2006), the court is constrained to interpret “depraved indifference” as a culpable mental state which must be proven by the People.