New York Law Review

Tag: People v. Matos

  • People v. Matos, 19 N.Y.3d 471 (2012): Depraved Indifference Requires Utter Disregard for Human Life

    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.

  • People v. Matos, 83 N.Y.2d 509 (1994): Establishing Causation in Felony Murder

    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.