## Facts

- A 17-year-old, heavily intoxicated and distraught teenager told Patrick Michael Duffy he wanted to kill himself.
- Duffy brought the teenager to Duffy’s second-floor apartment, gave him more alcohol, and repeatedly encouraged self-harm, including challenging him to jump headfirst from a second-story porch.
- Duffy retrieved a rifle and ammunition, handed them to the teenager, and urged him to place the gun in his mouth and shoot himself.
- The teenager loaded the rifle, pulled the trigger, and later died from the injuries.
- Duffy was indicted for second-degree manslaughter on two theories: intentional causation or aiding of suicide (Penal Law § 125.15(3)) and reckless causation of death (Penal Law § 125.15(1)).
- The jury acquitted Duffy of intentional aiding of suicide but convicted him of reckless manslaughter.
- The Appellate Division reversed and dismissed, reasoning suicide-related conduct could be prosecuted, if at all, only under the aiding-suicide subdivision.
- The People appealed to the New York Court of Appeals.

## Issues

1. Whether Penal Law § 125.15(1) permits a second-degree manslaughter conviction when the defendant’s reckless conduct results in another person’s suicide.
2. Whether the victim’s voluntary act of suicide necessarily breaks causation, or whether the defendant’s conduct can be a sufficiently direct cause of death to sustain reckless manslaughter.

## Decision

- The Court of Appeals reversed the Appellate Division and reinstated the reckless manslaughter conviction, remitting for further review of facts.
- Penal Law § 125.15(1) is not displaced by § 125.15(3); a suicide does not categorically bar prosecution for reckless homicide when the statutory elements are proven.
- The evidence permitted the jury to find Duffy acted recklessly by consciously disregarding a substantial and unjustifiable risk of death.
- The victim’s suicide did not, as a matter of law, constitute a superseding cause; Duffy’s conduct could be found a sufficiently direct and foreseeable cause of death.

## Legal Principles

- Second-degree manslaughter under Penal Law § 125.15(1) can apply where a defendant’s reckless conduct is a sufficiently direct and reasonably foreseeable cause of another’s suicide.
- The existence of a specific offense for intentionally causing or aiding suicide (Penal Law § 125.15(3)) does not preclude liability under the reckless-homicide provision when its elements are independently satisfied.
- Proximate cause in homicide does not require the defendant’s conduct to be the sole cause; the question is whether the result is too extraordinary or remote to impose liability.
- A victim’s voluntary act, including suicide, does not automatically sever causation; the causal analysis is fact-specific.
- An acquittal on an intentional-aiding-suicide count does not bar conviction for reckless manslaughter based on a different culpable mental state.

## Conclusion

The court held that reckless manslaughter may be sustained where a defendant’s conduct—such as supplying a firearm and urging its use—creates a substantial, unjustifiable risk of death and is a sufficiently direct, foreseeable cause of a victim’s suicide, notwithstanding the separate statutory provision addressing intentional aiding of suicide.


People v. Duffy, 79 N.Y.2d 611 (N.Y. 1992)