People v. Matos, 83 N.Y.2d 509 (1994)
A defendant is culpable for felony murder when their actions set in motion a chain of events that directly and foreseeably leads to another’s death, even if the defendant’s actions are not the sole or final cause of death.
Summary
Eddie Matos was convicted of felony murder after a police officer died while pursuing him on a roof following a burglary. Matos and accomplices broke into a McDonald’s, and a responding officer, Dwyer, fell to his death down an airshaft while in pursuit of Matos on the roof. The New York Court of Appeals affirmed the conviction, holding that Matos’s actions initiated a foreseeable chain of events leading to Dwyer’s death. The court emphasized that the defendant’s conduct must be a sufficiently direct cause of the death and that the ultimate harm should have been reasonably foreseen, even if it wasn’t the most likely outcome.
Facts
In October 1989, Eddie Matos and two accomplices broke into a McDonald’s restaurant in Manhattan using a sledgehammer. They rounded up employees at gunpoint. A maintenance worker escaped and returned with three police officers. The officers saw Matos running towards the back of the restaurant and climbing a ladder to the roof. Officer Dwyer pursued Matos up the ladder. Shortly after, another officer found Dwyer lying dead at the bottom of an airshaft on the roof.
Procedural History
Matos was convicted in the trial court of second-degree murder, second-degree burglary, and attempted robbery. The Appellate Division affirmed the conviction. The New York Court of Appeals granted leave to appeal.
Issue(s)
Whether a fleeing felon’s actions are a sufficiently direct cause of another’s death when a police officer pursuing the felon dies during the pursuit, for the purposes of Penal Law § 125.25 (3), the felony murder statute.
Holding
Yes, because Matos’s actions set in motion a foreseeable chain of events that led to the officer’s death. His commission of a violent felony and subsequent attempt to escape directly caused the officer to pursue him onto the roof, where the officer fell to his death.
Court’s Reasoning
The Court of Appeals reasoned that for criminal responsibility to attach, a defendant’s actions must be an actual contributory cause of death. The defendant’s acts need not be the sole cause of death, but they must set in motion the events that ultimately result in the victim’s death. The court emphasized that the defendant’s conduct must be a “sufficiently direct cause” of the death, meaning the ultimate harm should have been reasonably foreseen.
The court distinguished the case from situations where the causal link is too attenuated. Instead, the court relied on precedents like People v. Kibbe, where abandoning a victim on the side of the road led to a foreseeable fatal accident, and People v. Hernandez, where a shootout initiated by the defendant led to an officer’s death, even though the fatal shot was fired by another officer.
The court stated, “[i]mmediate flight and attempts to thwart apprehension are patently within the furtherance of the cofelons’ criminal objective.” Foreseeability does not require the result to be the most likely event, only a reasonably possible one.
The court concluded that it was foreseeable that an officer would pursue Matos onto the roof during his escape. Given those circumstances, it was also foreseeable that someone might fall during the pursuit across urban roofs at night.