People v. Eulo, 63 N.Y.2d 341 (1984)

A person is considered legally dead when there is irreversible cessation of either cardiorespiratory functions or the entire brain’s functions, including the brain stem; therefore, a defendant is not relieved of homicide liability when a victim’s organs are removed after being declared brain dead, even if life support maintained heartbeat and breathing.

Summary

Defendants, charged with homicide, argued their conduct did not cause death because the victims were on life support when organs were removed. The New York Court of Appeals held that death occurs when there is irreversible cessation of either cardiorespiratory functions or the entire brain’s functions. The Court reasoned that modern medicine can artificially maintain these functions, necessitating brain-based criteria. The court emphasized that this ruling addresses *when* death occurs, not *when* a person may be allowed to die, affirming that the law’s focus remains on holding individuals accountable for actions leading to a victim’s death, regardless of life support or organ donation.

Facts

People v. Eulo: Eulo shot his girlfriend in the head. At the hospital, she was put on a respirator. Neurological tests showed no brain activity. Two days later, a second neurosurgeon confirmed the irreversible cessation of brain function. She was pronounced dead, although still on a respirator, and organs were removed. The respirator was then disconnected.
People v. Bonilla: Bonilla shot a man in the head. The victim was hospitalized and placed on a respirator. Neurological exams revealed no brain function. The next day, the tests were repeated with the same results, and the victim’s mother consented to organ removal. Death was pronounced after the second tests, organs were removed, and the respirator disconnected.

Procedural History

People v. Eulo: Eulo was convicted of manslaughter; the Appellate Division affirmed.
People v. Bonilla: Bonilla was convicted of manslaughter and weapons possession; the Appellate Division affirmed (split decision). The Court of Appeals consolidated the appeals due to the similarity of the issues.

Issue(s)

Whether, in the context of homicide, death occurs only upon irreversible cessation of cardiorespiratory functions, or whether irreversible cessation of all brain function, including the brain stem, also constitutes death?

Holding

Yes. The Court held that death occurs when there is irreversible cessation of either cardiorespiratory functions or the entire brain’s functions, including the brain stem, because the traditional definition of death must adapt to modern medical realities where machines can artificially maintain breathing and heartbeat.

Court’s Reasoning

The Court reasoned that while death was traditionally defined by cessation of breathing and heartbeat, medical advancements necessitate a more nuanced approach. Machines can now artificially maintain these functions, masking the true absence of life. The Court emphasized that the legal definition of death must align with contemporary medical standards, acknowledging brain death as a valid criterion. The Court stated, “Considering death to have occurred when there is an irreversible and complete cessation of the functioning of the entire brain, including the brain stem, is consistent with the common-law conception of death”. The court further stated, “When, however, the respiratory and circulatory functions are maintained by mechanical means, their significance, as signs of life, is at best ambiguous. Under such circumstances, death may nevertheless be deemed to occur when, according to accepted medical practice, it is determined that the entire brain’s function has irreversibly ceased.” The Court rejected the argument that organ removal constituted a superseding cause of death, provided that the victims were properly diagnosed as brain dead before the procedure. The Court clarified that this decision pertains to determining *when* death occurs, not *when* a person should be allowed to die, reinforcing the principle of holding individuals accountable for actions that cause death.