P, a doctor, was in a car accident which was D's fault. P believed he was unharmed.
After the accident, P began having seizures. After seven months, he had already had 38 seizures.
One day, P had 3 seizures. He killed himself.
P sued D for wrongful death.
Procedural History:
Trial court found for P.
Appellate court reversed, ordered new trial.
NY COA reversed, found for P.
Issues:
Is suicide an intervening or superseding cause?
Holding/Rule:
Suicide is usually a superseding cause and breaks the causation chain unless, because of the mental derangement, P was incapable or resisting the impulse to destroy himself.
Reasoning:
When the suicide is preceded by a history of trauma, brain damage, epileptic seizures, aberrational conduct, depression, then it is at the very least a fiar issue of fact whether the suicide was the rational act of a sound mind or the irrational act of a deranged mind.
Dissent:
None.
Notes:
This was a cutting edge case in finding that suicide might not break the causal chain.
