98 N.Y.2d 373 (2002)

Depraved indifference murder requires proof of recklessness so extreme that it demonstrates indifference to human life, focusing on the objective circumstances of the risk, not merely intent to cause harm.

Summary

Oswaldo Sanchez was convicted of depraved indifference murder for fatally shooting Timothy Range after an argument. The Court of Appeals affirmed the conviction, holding that a jury could reasonably find Sanchez acted recklessly, with depraved indifference, rather than intentionally. The court emphasized that depraved indifference murder requires an objective assessment of the risk created by the defendant’s conduct and rejected the argument that the act was purely intentional. This case distinguishes depraved indifference murder from both intentional murder and manslaughter by emphasizing the exceedingly high risk of death.

Facts

• Defendant Sanchez and victim Range were boyfriends of two sisters.
• At a birthday party, Range accused Sanchez of infidelity, leading to a heated argument and scuffle.
• Eyewitness testimony indicated Sanchez briefly walked away from Range, then turned back and shot him in the chest at close range.
• The bullet’s trajectory indicated the gun was fired at an angle.
• Sanchez claimed the shooting was accidental during a struggle for the gun.

Procedural History

• Sanchez was indicted on charges of intentional murder and depraved indifference murder.
• The trial court charged manslaughter as a lesser-included offense.
• The jury acquitted Sanchez of intentional murder but convicted him of depraved indifference murder.
• The Appellate Division affirmed the conviction.
• The New York Court of Appeals affirmed the Appellate Division decision.

Issue(s)

1. Whether the evidence was legally sufficient to support a conviction for depraved indifference murder, specifically whether there was a reasonable view of the evidence that the killing was reckless rather than intentional.
2. Whether the record contained sufficient evidence of “circumstances evincing a depraved indifference to human life.”

Holding

1. Yes, because viewing the evidence favorably to the prosecution, a rational jury could doubt that the homicide was intentional given prior cordial relations, the suddenness of the shooting, and the trajectory of the bullet.
2. Yes, because shooting the victim in the torso at point-blank range presented a transcendent risk of death, satisfying the manifested depravity requirement for depraved indifference murder.

Court’s Reasoning

The Court of Appeals focused on whether the act demonstrated a depraved indifference to human life, and differentiated this from intentional murder. The court stated that it was possible for the jury to determine that the defendant’s actions were reckless, not intentional, based on the evidence. The court reasoned that “circumstances evincing” depraved indifference refers to the factual setting, objectively assessed, and not to the subjective intent of the defendant. They pointed out that this case met the requirements for an exceedingly high risk of death, which establishes the degree of recklessness needed to establish the circumstances evincing depraved indifference to human life. The court emphasized that extremely reckless conduct is qualitatively different from manslaughter and equated it with intentional homicide. Quoting People v. Register, 60 N.Y.2d 270, 277 (1983), the Court explained that the focus is “upon an objective assessment of the degree of risk presented by defendant’s reckless conduct.” Dissenting opinions argued that the evidence pointed to intentional murder and that the depraved indifference charge was inappropriate, as it blurred the lines between intent and recklessness and essentially allowed for a depraved indifference murder conviction in nearly any shooting death.