New York Law Review

Tag: Suicide

  • Wellisch v. John Hancock Mut. Life Ins. Co., 293 N.Y. 178 (1944): Admissibility of Expert Testimony on Suicide

    293 N.Y. 178 (1944)

    In cases involving potential suicide, expert testimony is admissible to assist the jury in understanding patterns of behavior and other circumstances surrounding the death that are not within the common knowledge of laypersons.

    Summary

    This case addresses the evidentiary standards for determining whether a death was accidental or a suicide, specifically concerning the admissibility of expert testimony. The court reversed the Appellate Division’s order, holding that the exclusion of expert opinion on whether the death was a suicide was an abuse of discretion. The court emphasized the jury’s role in resolving doubts when a reasonable hypothesis of accidental death exists, but also acknowledged the necessity of expert guidance on matters beyond common knowledge. The ruling underscores the importance of expert testimony in informing juries about behavioral patterns and circumstances surrounding potential suicides.

    Facts

    The decedent died under circumstances suggesting a possible drug overdose. The central dispute was whether the death was accidental or a suicide. The trial involved conflicting evidence and hinged on the interpretation of circumstances surrounding the death. The key evidence included the level of toxicity found in the decedent’s body and observations about the scene where the body was discovered.

    Procedural History

    The case originated in a lower court, where a jury verdict was reached. The Appellate Division reviewed the case and issued an order. The Court of Appeals then reviewed the Appellate Division’s order. The Court of Appeals reversed the Appellate Division’s order and granted a new trial, finding that the exclusion of certain expert testimony was an error.

    Issue(s)

    1. Whether the evidence presented a fair question of fact as to whether the death was accidental, considering the presumption against suicide?

    2. Whether the exclusion of expert testimony regarding whether the death was a suicide constituted an abuse of discretion?

    3. Whether the redaction of the death certificate and autopsy report to omit the “suicide” conclusion was an error?

    Holding

    1. Yes, because on the record and considering the strong presumption against suicide, a fair question of fact as to accident had been presented.

    2. Yes, because whether the number of pills required to reach the level of toxicity found in decedent’s body could have been taken inadvertently or whether the circumstances surrounding the body were consistent with general patterns of behavior exhibited by other suicide victims were not matters within the jury’s common knowledge.

    3. Yes, because the Trial Judge agreed that redaction of the death certificate and autopsy report, both signed by Dr. Baden, to omit the “suicide” conclusion was error.

    Court’s Reasoning

    The Court reasoned that a jury question existed because there was a reasonable hypothesis of accidental death, and it is the jury’s duty to resolve the doubt. The Court found that the exclusion of Dr. Baden’s expert opinion was an abuse of discretion. The Court stated, “Although the jury may have been able to evaluate some of the evidence presented, whether the number of pills required to reach the level of toxicity found in decedent’s body could have been taken inadvertently or whether the circumstances surrounding the body were consistent with general patterns of behavior exhibited by other suicide victims were not matters within their ken.” The Court highlighted that some issues required expert knowledge because they were not within the average person’s understanding. This made expert testimony crucial. The court also noted the error in redacting the death certificate and autopsy report to omit the “suicide” conclusion because they were official records created by the same expert whose testimony was excluded.

  • Matter of Ferdinandiewicz v. General Aniline & Film Corp., 11 N.Y.2d 890 (1962): Causation Between Workplace Injury and Suicide

    Matter of Ferdinandiewicz v. General Aniline & Film Corp., 11 N.Y.2d 890 (1962)

    For a suicide to be compensable under workers’ compensation, it must result from a work-related injury that causes a brain derangement or psychosis, not merely from discouragement or melancholy.

    Summary

    This case addresses the causal link between a workplace injury and suicide in the context of workers’ compensation. The Court of Appeals affirmed an award of death benefits to the widow of an employee who committed suicide, finding a sufficient causal connection to prior work-related accidents. The dissent argued that the suicide was not a result of brain derangement caused by the accidents, but rather stemmed from the employee’s life circumstances and a lack of substantial evidence linking the accidents to a qualifying mental state.

    Facts

    The deceased employee committed suicide by taking an overdose of barbiturates. Prior to his death, he had sustained two work-related accidents: a back injury in 1954 and a cerebral concussion in 1945. The Workmen’s Compensation Board attributed 75% of the death award to the 1954 back injury and the remainder to the 1945 concussion. The employee had a complex history, including being raised as a foster child, suffering from rickets, and undergoing surgery for a polyp in his ear. He also had pre-existing complaints of headaches, blackouts, and nervousness before the 1945 accident, for which he sought treatment at a mental hygiene clinic.

    Procedural History

    The Workmen’s Compensation Board awarded death benefits to the employee’s widow. The appellate division affirmed this decision, leading to an appeal to the New York Court of Appeals, which affirmed the appellate division’s order.

    Issue(s)

    Whether there was sufficient causal connection between the employee’s work-related accidents and his subsequent suicide to justify an award of death benefits under the Workmen’s Compensation Law.

    Holding

    Yes, because the court found sufficient evidence in the record to support the determination that the work-related accidents contributed to a mental state that led to the employee’s suicide.

    Court’s Reasoning

    The court majority found that a causal connection existed, implicitly accepting the Board’s findings. The dissent, however, argued that the suicide was not the result of a “brain derangement” as required by prior case law, but rather stemmed from the employee’s life circumstances and pre-existing mental health issues. The dissent emphasized Section 10 of the Workmen’s Compensation Law, which states that there is no liability when the injury has been solely occasioned by the willful intention of the injured employee to bring about the injury or death of himself. The dissent cited several cases, including Matter of Delinousha v. National Biscuit Co., for the proposition that suicide is only compensable if it results from a brain derangement caused by the injury, not merely from “discouragement, or melancholy, of other sane conditions.” According to the dissent, expert opinions lacking probative force, being “contingent, speculative, or merely possible,” cannot establish causation, quoting Matter of Riehl v. Town of Amherst. The dissent highlighted the lack of evidence showing psychosis or brain damage directly resulting from the accidents, suggesting that the employee’s suicide could be attributed to his difficult life experiences and pre-existing mental health issues. The dissent concluded that it was mere guesswork to attribute the employee’s suicide to the accidents rather than his other misfortunes.

  • Mason v. Williams, 131 A.D. 131 (N.Y. App. Div. 1909): Testamentary Capacity and Suicide

    131 A.D. 131 (N.Y. App. Div. 1909)

    Suicide alone does not establish lack of testamentary capacity, and a will made by a person contemplating suicide is not automatically invalid unless made under undue influence or lacking testamentary capacity.

    Summary

    This case concerns a challenge to the validity of a will of a testator who died by suicide shortly after executing a codicil. The defendants contested the will, alleging lack of testamentary capacity, undue influence, and that the will was made with suicidal intent, rendering it against public policy. The court affirmed the judgment upholding the will’s validity, holding that suicide alone does not prove lack of testamentary capacity and that there was no evidence to support the claims of undue influence or that the will was made with suicidal intent so as to be against public policy. The court emphasized the absence of any manifest mental derangement beyond the act of suicide itself. The Appellate Division found no basis to overturn the lower court’s decision.

    Facts

    Henry T. Bason, a county judge, executed a will in November 1902 and a codicil in March 1903. He died by suicide shortly after executing the codicil. The will primarily bequeathed his property to his mother; the codicil made specific gifts to various individuals and entities. Bason had been a patient at a sanitarium for neurasthenia (nervous exhaustion) before executing the will. Defendants, distant relatives, challenged the will’s validity, alleging Bason lacked testamentary capacity and was unduly influenced.

    Procedural History

    The will and codicil were admitted to probate in the Surrogate’s Court. The plaintiff, as executor, initiated an action under section 2653a of the Code of Civil Procedure to establish the validity of the probate. The trial court directed a verdict sustaining the will. The contesting defendants appealed to the Appellate Division of the Supreme Court.

    Issue(s)

    1. Whether the mere act of suicide shortly after executing a will and codicil establishes a lack of testamentary capacity.
    2. Whether a will made with suicidal intent is void as against public policy.
    3. Whether there was sufficient evidence of undue influence to invalidate the will.

    Holding

    1. No, because insanity is not inferable from the mere act of suicide, and there was no other evidence of mental unsoundness.
    2. No, because the record shows no evidence to suggest that either instrument was drafted or executed with suicidal intent. Further, even if the testator contemplated suicide, the will disposes of his property as he might do during his lifetime, conferring no benefits that he might not bestow without any suicidal intent.
    3. No, because the claim of undue influence was unsupported by proof, and the disposition of property was a natural one.

    Court’s Reasoning

    The court reasoned that the mere fact of suicide does not justify an inference of lack of testamentary capacity. It cited Weed v. Mutual Benefit Life Ins. Co., 70 N.Y. 561 and Shipman v. Protected Home Circle, 174 N.Y. 398, to support the principle that insanity is not inferable from suicide alone. The court distinguished Riggs v. Palmer, 115 N.Y. 513, noting that in Riggs, the beneficiary committed a crime (murder) to obtain property, whereas in the present case, the testator’s suicidal intent did not directly affect the disposition of property in a way that violated public policy. The court found no evidence of undue influence, noting that the testator left his property to friends, associates, and charities in a manner consistent with his interests during his lifetime. The court emphasized that the defendants failed to demonstrate any manifestation of mental derangement beyond the act of suicide and some prior treatment for neurasthenia. The court stated, “Mental derangement cannot be predicated solely upon the circumstance that he killed himself. Insanity is not inferable from the mere act of suicide.”