People v. Ingram, 67 N.Y.2d 897 (1986)

In a felony murder case, the prosecution must prove beyond a reasonable doubt that the defendant’s actions during the commission of the felony directly caused the victim’s death, but the exact manner of death need not be foreseeable.

Summary

Ingram was convicted of felony murder and burglary after Melvin Cooper died of a heart attack shortly after Ingram burglarized his home. Cooper, who had a history of heart trouble, collapsed after confronting Ingram, who had broken into his residence. The Court of Appeals affirmed the conviction, holding that the prosecution presented sufficient evidence to prove that Ingram’s actions during the burglary caused Cooper’s death. The court also noted that the defense failed to preserve objections regarding the foreseeability of the manner of death and the severity of the sentence.

Facts

Ingram and his companions surveyed Melvin Cooper’s house before breaking in to determine if anyone was home. Their activities awakened Cooper, who confronted Ingram inside the house with a gun. Cooper ordered Ingram to lie down and then called the police. After the police arrested Ingram, Cooper collapsed and died shortly afterward at the hospital. Cooper had a pre-existing heart condition. The prosecution argued that the stress of the burglary caused Cooper to suffer a fatal myocardial infarction.

Procedural History

Ingram was convicted of felony murder and burglary in the trial court. He appealed, arguing that the prosecution failed to prove causation. The Appellate Division affirmed the conviction. Ingram then appealed to the New York Court of Appeals.

Issue(s)

1. Whether the People presented sufficient evidence to prove that the defendant caused the victim’s death during the course of a burglary.
2. Whether the defendant may be guilty of felony murder only if the fact of death and the manner in which it occurred was a foreseeable consequence of the burglary.
3. Whether the defendant’s sentence constituted cruel and inhuman punishment.

Holding

1. Yes, because the People presented sufficient medical evidence linking the stress of the burglary to the victim’s myocardial infarction.
2. This issue was not preserved for review because the defense failed to object to the jury charge or request additional instructions.
3. This issue was not properly before the court because the defendant failed to challenge his sentence before the trial court.

Court’s Reasoning

The Court of Appeals held that the prosecution’s medical expert provided sufficient evidence to link the burglary to Cooper’s death. The expert testified that Cooper’s myocardial infarction was precipitated by the stress of finding a burglar in his home. The court stated that the expert’s testimony was not “so baseless or riddled with contradiction that it was unworthy of belief as a matter of law” (citing People v Anthony M., 63 NY2d 270, 281; People v Stewart, 40 NY2d 692, 699). The court found it insignificant that there was a lack of postmortem clinical signs of an infarction. The expert clarified that such signs do not appear unless death occurs at least 12 hours after the incident.

Regarding foreseeability, the Court found that the defendant’s argument wasn’t preserved, because his counsel didn’t challenge the given charge or request supplementary directions. Similarly, his claim that the sentence was cruel and inhumane wasn’t reviewed as it wasn’t raised initially in the trial court.