Commonwealth v. Carlson

Facts

Carol Suprenant was diagnosed with chronic obstructive pulmonary disease and depended heavily on an oxygen tank to aid her in breathing. Suprenant’s disease was worsening. Thus, Suprenant told her relatives that she did not want to be kept alive with a ventilator. Subsequently, Suprenant and her husband were on their way to a barbeque when Carlson, Defendant, drove through a stop sign, causing Defendant’s vehicle to strike with the passenger side of Suprenant’s vehicle. At that time, Suprenant was sitting in the passenger seat of the vehicle; therefore, she was injured and endured multiple chest-wall fractures. On the same day, Suprenant was taken to an intensive care unit and placed on a ventilator. The following morning, Suprenant was removed from the intensive care unit, and she was removed from the ventilator. Thereafter, Suprenant had trouble, and doctors urged her to begin using the ventilator again. Nevertheless, Suprenant opposed the use of the ventilator at first, however, after her family members and doctors continued to urge her to use the ventilator, she began to use it again. Nonetheless, the subsequent day, Suprenant’s kidneys started to fail, causing Suprenant to choose to be removed from the ventilator. Suprenant refused to continue being on the ventilator and dialysis to evaluate whether her condition could improve. The doctors discussed Suprenant condition with her, making Suprenent aware that her refusal to be on the ventilator and dialysis would likely result in her death. Likewise, Suprenant knew that the more she used the ventilator the more likely she would survive her condition, even with a reduced breathing capacity. Moreover, Suprenant died a few hours after she was removed from the ventilator. Later, Defendant was charged and convicted of motor-vehicle homicide by negligent operation, and Defendant appealed the decision alleging he did not cause Suprenant’s death.