Colorado Law Blog

A horrific tale most appropriate for Hallow's Eve - on February 23, 2006 in Brooklyn State Supreme Court, four men were arraigned on a series of charges reading like Robert Louis Stevenson’s saga The Body Snatchers. Prosecutors claimed that the men, who worked for a company called Biomedical Tissue Services, had engaged in a modern form of body-snatching. A ghoulish ring trafficking in bones, tissue and other body parts illicitly harvested from corpses at funeral homes throughout New York City potentially raked in millions of dollars selling tendons and ligaments for surgical replacement and bone for dental implants and orthopedic reconstruction procedures, sources familiar with the investigation said.

It is illegal, under federal law, to sell any body parts for profit. To make the donation acceptable to tissue-processing companies, the scheme also allegedly involved the creation of forged relatives' consent forms and phony records to change the medical condition and cause of death of the deceased.

According to the indictment, they had paid $1,000 per body to 30 or 40 funeral homes in the New York and Philadelphia areas. Then—without consent of the families of the deceased—they used scalpels, mallets, scissors, and saws to remove the organs, tissue, and bones, which they sold for transplant, research, and medical education.

The indictment also alleges that the men misrepresented the age, cause of death, and health status of the corpses. After mining the bodies for valuable parts, they sent them off for cremation. If a funeral was intended, they inserted PVC plumbing pipe in place of the bones and sewed the body back up.

The state charged the four men with crimes that included enterprise corruption, body-stealing, opening graves, unlawful dissection, and forgery. An exceptionally ghoulish example of unscrupulous business practices, the Biomedical Tissue Services scandal is also just one instance of legal problems related to the collection and distribution of human tissue. Unethical practices in the tissue industry have grown, just as the value of human tissue, from both living and dead donors, has increased dramatically in the biotech era. A single cadaver can be mined for medical and research uses—its skin is worth $36,522, its bones $80,000, its tendons $21,400, and so forth. The value of a particularly interesting human gene can be billions of dollars.

Whose Body Is It?

The legal system is beginning to address how human tissue is acquired, what it is used for, and how to protect people who receive it—whether as a transplant, a transfusion, a bone graft, an embryonic stem cell line, a gene therapy, or even a biotech pharmaceutical product.

Without a property interest in their tissue, people are not adequately protected. The legal issues are even more challenging when the tissue source (that is, the person) is dead. At the Saginaw Community Hospital in Michigan, Armando Herrera was an assistant to the pathologist who conducted autopsies. Herrera’s job was to open up the bodies and then, after the pathologist had finished work, sew them back up. But Herrera had another job: He owned and operated the Central Michigan Eye Bank and Tissue Center. So when the autopsies were over, and without informing anyone, he would remove the deceased’s eyes and sell them.

Relatives of Herrera’s deceased victims later sued, but the trial court dismissed their claims because a relative’s interest in a next of kin’s body was not a “property interest” under the Fourteenth Amendment’s Due Process Clause. The Sixth Circuit, however, was clearly troubled that people might not be protected if their bodies could not be considered property. If a woman’s husband died in a neighbor’s yard, one justice asked, should the neighbor simply be able to keep the body? To the appellate court, the answer was clear. Unanimously, the court ruled for the first time that next of kin have “a constitutionally protected property interest in the dead body of a relative.”

Most people whose tissue is mined for patentable genes do not even know they have been donors. When a person has a blood test or biopsy at a hospital, that tissue is often used for research or sold to biotechnology companies. Over 282 million archived and identifiable pathological specimens, from more than 170 million people, are currently stored in the United States.16 At least 20 million new specimens are added each year.

The unwitting recipient of a human tissue product also faces risks. In Germany, one of the prime users of surreptitiously collected tissue was Braun Pharmaceuticals, which made Lyodura, a product made with donated dura mater (brain tissue) and used to replace damaged tissue in patients. After 43 patients died of Creutzfeldt-Jakob Disease (CJD), a rare degenerative brain disorder, from dura transplants, Braun stopped distributing Lyodura. Similarly, in Britain, infertile women who received injections to help them ovulate were not told that the injections came from the pituitary glands of human corpses. Now, some of those women are dying of CJD.

Existing U.S. laws do not require doctors to tell patients if their treatments are made from body tissue, and these treatments are not subject to the same FDA approval standards that drugs and medical devices are. European law is far stricter. A European Commission document recommended that the use of certain tissue, such as dura mater and auditory ossicles, be “banned or at least limited” because valid tests are not available to ensure that the tissue is disease-free.

The creation of commercial products from human tissue has raised Frankensteinian questions about profit and property, consent and control, and ownership of the human body. In legal and social disputes over body parts, people are asking whether tissue and genes are intrinsic to the person and their humanness or, “the currency of the future,” as claimed by one modern Dr. Frankenstein, the director at pharmaceutical giant SmithKline Beecham.

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The Insurance Institute for Highway Safety estimates more than 1.5 million deer collisions take place each year in the United States, costing approximately $1.1 billion in vehicle damage. In Michigan, the Michigan Deer Crash Coalition estimates that one in seven reported crashes in that state involves a deer -- one every eight minutes. Informal surveys suggest that the actual number may be quite higher, with nearly as many collisions unreported, either because the owner isn't required to by law or because he doesn't have insurance.

The Center for Disease Control has found that one quarter of all animal-vehicle collisions result in human injury. $2,800 is the average cost per insurance claim on a vehicle involved in a collision with an animal. With injury claims, the total reaches $11,000 per collision, the Insurance Information Institute says.

Approximately 200 deaths per year are caused by animal-vehicle collisions, according to the National Highway Traffic Safety Administration, up from an average of 119 deaths per year in 1993-1997, and an average of 155 between 1998-2002.

Colorado Statistics

26,190 animal-vehicle collisions were reported on Colorado's roadways in the twelve years spanning 1993 to 2004. According to the Colorado Department of Transportation (CDOT), October and November see more animal-vehicle collisions than any other time of year. 490 such collisions were reported across the state in October 2004, and 580 in November 2004.

In Colorado, 25 people were killed in animal-vehicle collisions from 1993-2004, 2,266 sustained injuries, and 22,388 experienced property damage, according to CDOT.

A study by the Southern Rockies Ecosystem Project, funded by the Federal Highway Administration, examined 100 known linkages, or commonly traveled pathways, between animal habitats and found many cross Colorado roads. The study identified the following locations as being extremely hazardous for drivers and wildlife:

I-70 at Floyd Hill/Mt. Vernon Canyon
US 285 at Morrison
HWY 160, Durango to Pagosa Springs and Durango to Mancos
HWY 550, North of Durango and Montrose to Ouray
I-25 Castle Rock to Larkspur
HWY 82 Glenwood Springs to Marble
HWY 36 Boulder to Lyons
I-70 Eagle

The problem intensifies during deer season -- from October through December -- when there is a dramatic increase in the movement of the deer population. Many of these deer find their way onto highways and into suburban neighborhoods.

Common Sense, Not Bells and Whistles

Few strategies for preventing deer-car collisions actually work, according to a 2003 IIHS study. It described deer fences -- chain link and at least 8 feet high -- as the only guaranteed way to keep deer off roadways. Other methods that may prove effective, the study said, include clearing ground alongside roads so that drivers will see nearby deer, and temporary signs (not the permanent, roundly ignored "Deer Crossing" markers) along migratory routes. A more expensive approach is installation of sensors that activate signs when deer approach.

The study firmly rejected "deer whistles" (whistles mounted on a car that produce an ultrasonic noise when a vehicle moves) as a deterrent.

Not surprisingly, to decrease the likelihood of hitting deer at times and places where deer are present requires common sense. Drive with caution when moving through deer-crossing zones, in areas known to have a large deer population or in areas where roads divide agricultural fields from forest. Deer often move in groups. If you see one, there are likely more in the vicinity. They tend to move in single file.

When driving at night, use high-beam headlights when there is no oncoming traffic. The high beams will better illuminate the eyes of deer on or near the roadway. Be especially attentive from sunset to midnight and during the hours shortly before and after sunrise. These are the highest risk times for deer-vehicle collisions.

Brake firmly when you notice a deer in or near your path, but stay in your lane. A deer typically weighs less than 200 pounds; another car will weigh at least 3,000 pounds. Your chances are a lot better if you hit the deer.

If you hit a deer, pull well off the road and turn on your emergency flashers.

Even if you are uninjured and your car is drivable, notify the police if the animal remains in the road. Don't try to remove a deer from the road unless you are sure that it is dead. An injured deer can thrash its hooves and severely injure you.

And finally, report the incident to your insurer. Typically damage is covered by the comprehensive portion of an auto insurance policy.

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You don’t have to spend much time on any major highway before you feel like your vehicle is about to be blown away by the semis racing past you. The American Trucking Associations, the nation’s premier trucking industry trade group, recognizes the significant public safety risk posed by these speed demons and last week petitioned the National Highway Traffic Safety Administration to limit the maximum speed of large trucks at the time of manufacture to no more than 68 miles per hour.

In a complementary move, ATA also petitioned the Federal Motor Carrier Safety Administration to prohibit the tampering or adjustment of the speed limiting devices, known as speed limiters (or governors), to greater than 68 miles per hour.

“For the sake of safety, there is a need to slow down all traffic,” said ATA President and CEO Bill Graves. “The trucking industry is trying to do its part with this initiative. No vehicle should be capable of operating at excessive speeds on our nation’s highways.”

ATA’s safety action is aimed at reducing the number and severity of speed-related crashes among all vehicles on U.S. highways. It is part of a comprehensive trucking industry highway safety initiative that has produced a record low crash rate. Other ATA safety initiatives include a call for universal primary safety belt laws in the 50 states and greater enforcement of traffic laws against unsafe driving actions around large trucks.

According to the ATA, the federal government’s lack of focus on speed in crashes involving large trucks represents a significant gap in its truck safety strategy. The majority of the federal truck safety budget is focused on ensuring safe equipment, driver fatigue and preventing impaired driving, which the industry supports. Research indicates, however, that speed is a more significant factor in crashes involving trucks than any other factor that currently receives a larger proportion of government attention and resources.

The American Trucking Associations, the national trade association for the trucking industry, is a federation of affiliated state trucking associations, conferences and organizations that represents more than 37,000 motor carrier members from every class of motor carriers.

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Caveat emptor that cadaver! A Connecticut Superior Court judge has ruled in favor of a business accused of providing a defective heart valve for transplantation, saying that such human tissue is not a product for the purposes of a product liability claim. The issue of whether to consider processed tissue a product has been addressed by only a handful of opinions—including a California case and a federal court interpreting Utah law and all have held as the Connecticut court did.

Judge Robert E. Beach Jr. granted summary judgment to CryoLife Inc., a processor of human tissue, holding that tissue for transplantation falls within the state’s blood-shield statute and is therefore not a product under Connecticut’s product liability law. Miller v. Hartford Hospital, No. CV04 4003261 S (Sept. 19).

The ruling has spurred debate over accountability in cases of negligence in handling human tissue. It also leaves the plaintiff with no remedy for damages allegedly caused by the heart valve.

The underlying idea of strict product liability is that a manufacturer is liable for a defect that can be taken out of a product if appropriately designed or manufactured. The FDA-regulated products like tissue are marketed by huge businesses that take tissue and transform it, and the multibillion-dollar tissue industry, under this ruling, will fall outside the product liability statutes because of old blood-shield statutes that were enacted before anyone anticipated the scope of preservation or manipulation of tissue.

Plaintiffs lawyers, however, say state blood-shield statutes like the one at issue in Miller were never intended to immunize companies like CryoLife from liability for alleged negligence. Such companies process human cadaver parts and are more than tissue banks, they contend.

Miller was brought by the administrator of the estate of Leonard Klein, who received an aortic valve harvested from a cadaver and prepared for transplantation by CryoLife, a Kennesaw, Ga., company that processes, preserves and distributes human tissue for cardiac and vascular surgeries, according to its Web site. Eight months after his March 2002 transplant, Klein died because the valve was infected with a fungus when transplanted, the plaintiff alleged. The administrator sued the surgeon, hospital and provider of the valve.

In granting summary judgment to CryoLife, the court rejected the plaintiff’s claim that the company’s processing of the valve transformed the tissue into a product. "This suggestion, though imaginative, is implausible," the court said. "There is … no question but that human tissue forms the basis" for the medical procedure at issue.

The post title is from the opening lines from THE TELL-TALE HEART by Edgar Allan Poe (1843.)

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During the 2005-2006 ski season, there were 23 fatalities in the United States due to avalanches. In Colorado, avalanches have occurred every month of the year. If you remember anything about avalanches remember this: avalanche danger is greatest during and shortly after intensive snow falls. Traveling on or below 30 degree slopes during intensive storms is very dangerous -intensive storms are those in which 1” of snow falls per hour.

Most avalanches start on slopes that are 30 degrees or greater. If you stay off of 30+ degree slopes and avoid traveling beneath them, your risk is greatly minimized. Wind moves snow from windward to leeward slopes and can create the same kinds of unsafe conditions created by an intensive snow fall. Stay off leeward slopes during periods of strong winds.

Snow Area Safety

Watch for the leeward pockets. Many mid and low elevation slopes have a lot of sagebrush showing, but every so often there are pockets—sides of gullies, steep short slopes and back sides of ridges—where the wind has deposited snow. Plan your route to avoid these areas.

One extremely dangerous time in the mountains occurs when a period of cold weather is followed by a sudden warming trend or rain falling on the snow pack. Free water in the snow pack lubricates weak layers and large avalanches often result. Like intensive storms, it is a very dangerous time to be traveling in the mountains.

Heavy trees provide protection from avalanches, but the trees must be spaced within 3 meters of one another. That’s close enough to make skiing annoying. Sparse trees do NOT provide any more protection than open slopes.

In the spring, big wet, damaging avalanches can occur. The safest time to travel is in the morning after a cold, clear night when the snow is frozen. Get off of steep slopes when the snow begins to soften from melting. Don’t camp, eat lunch and rest below obvious avalanche paths.

Traveling alone is risky: two is better, three is better yet. Use ridge lines, heavy trees, windward sides or low angle slopes (less than 30 degrees) to minimize your exposure. When crossing suspected avalanche slopes, do so one person at a time. A slope is not safe just because one or more individuals have crossed it, and remember to travel from island of safety (a group of heavy trees, a ridge top, etc) to island of safety.

Carry emergency avalanche equipment: transceiver, portable shovels, probe poles—and for a hasty snow pit: hand lens, pencil, knife, and compass with inclinometer. At the beginning of each winter season practice with your transceiver. Know how to use it before you need to use it.

If you are moving up or down a suspected slope, stay to the side. If an avalanche occurs, the snow may move slower on the flank and allow escape. Stay out of gullies. They are natural pathways for avalanches and often fill deeply with snow when an avalanche occurs.

Know what’s out there. Check the avalanche forecast before leaving on a backcountry trip. In Colorado, check the Colorado Avalanche Information Center for up to the minute weather and conditions during the ski season.

Posted by Linda Chalat at 02:06 PM | Permalink | Comments (0) | TrackBacks (0)

Many different groups of people, including the very young, participants over age 60, the handicapped and the disabled enjoy ski/snowboard activities. Approximately 10.4 million Americans either ski or snowboard. Final reports indicate that the U.S. ski industry set an all-time national skier visit record of 58.8 million for the 2005/06 season, up 3.5 percent from last season, and up 2.3 percent from the previous record set in 2002/03. As many participants now snowboard as ski. But a day on the slopes can end in the emergency room, or worse. On average, 34 people die each year in the United States while skiing or snowboarding. Another 39 suffer severe, yet nonfatal, injuries, including paralysis and brain trauma.

When an accident occurs, ski law covers a broad continuum of claims and duties of care. Downhill skiing accidents involve the most restricted duty analysis as claims are limited by assumption of risk/inherent danger rules. Vehicle, snow groomer, and snowmobile cases, along with skier versus skier collisions and other “co-participant cases” are governed by rules of reasonable care owed by all participants. Ski lift/tramway accidents impose the highest duties of care upon the ski area operator.

Ski law is local law. It varies from state to state. Each state’s statutory, common law, and regulatory schemes apply different treatment to the duties, immunities, and liabilities of ski area operators, lift operators, skiers, snowboarders, and related parties.

Most states with a ski industry have a specific ski statute, modeled on an operator immunity framework advanced by industry lobbyists. However each statute evolved differently and typically each state has a body of interpretative case law, relating to skiing. Generally, these statutes establish safety requirements for operating equipment and vehicles, marking, signs and other minimal duties on the operators, otherwise, all risks are purportedly transferred onto the skier. Several states with significant ski economies, including California, have no statewide statutory scheme, although in California local ordinances offer legislative authority.

Some states, such as Michigan, employ an assumption of risk or inherent risk doctrine to protect the ski areas against claims arising from almost any injury claim, on the premise that any injury while downhill skiing or snowboarding is inherent in the sport.

Colorado mandates minimal safety standards for the operation of the ski areas, principally with regard to signs, warnings, markings on trails, which if specifically violated, will form the basis for a claim against a ski area operator, for a downhill skiing/snowboarding accident.

Most states hold skiers & snowboarders financially responsible to other skiers for their negligent skiing which results in a skier/skier collision. But several states have held that skiing is a “limited contact” sport and require proof of recklessness in order to recover from a collision between participants. In most states with a substantial skiing industry, ski area operators must meet higher standards of care in the operation, use and maintenance of lifts, trams and tows.

How to avoid learning first-hand about intricacies of ski law?

Follow these simple rules:
1. Wear a helmet. Helmets have been proven to reduce or prevent head injuries.
2. Take a ski lesson. Those short fat skis may seem easier to turn and control, but if you take a lesson, you will ski better and more safely.
3. Carry some basic first aid and survival gear: a small first aid kit, space blanket, whistle, medications such as an inhaler if you are asthmatic, insulin if diabetic, etc. Bring your cell phone.
4. Carry a ski area map.
5. Maintain your equipment either yourself or professionally. Make sure your bindings are in the DIN recommended for you, and are clean and functioning.
6. Wear proper clothing and eyewear. Cotton jeans and sweatshirts are not good ideas. They absorb water and turn into refrigerants. At high altitude - a decent pair of polarized goggles or sunglasses are inexpensive and may save your eyesight.
7. At large ski areas, where there is a risk of getting lost, isolated, or in a spot where you won't be seen, don't ever ski alone, and never abandon a buddy.
8. Don't ski while listening to music on a headset.
9. Ski sober. Don't smoke dope, or drink booze when skiing.
10. Obey the NASA code of safety:

• Always stay in control, and be able to stop or avoid other people or objects.


• People ahead of you have the right of way. It is your responsibility to avoid them.


• You must not stop where you obstruct a trail, or are not visible from above.


• Whenever starting downhill or merging into a trail, look uphill and yield to others.


• Always use devices to help prevent runaway equipment.


• Observe all posted signs and warnings. Keep off closed trails and out of closed areas


• Prior to using any lift, you must have the knowledge and ability to load, ride and unload safely.

If you see a ski area operator employee doing something which is unsafe, like driving a groomer uphill against skier traffic on an open slope - say something to the management of the ski area. They like to prevent accidents as well.

Posted by Linda Chalat at 11:48 AM | Permalink | Comments (0) | TrackBacks (0)

The classic Halloween image is that of a broadly smiling Jack-O-Lantern, animated by a burning candle. But, reported home candle fires have tripled since their low in 1990. Two-fifths started in the bedroom, while the living room, family room, or den was the leading area of origin for candle fire deaths. Half of the home candle fires occurred after by some type of combustible was too close to the candle; an unattended or abandoned candle was a factor in 18% of these fires. Falling asleep was a factor in 12% of the incidents.

To avoid becoming a fire victim, use flashlights when illuminating Jack-O-Lanterns. Use extreme caution when decorating with candle lit Jack-O-Lanterns, and supervise children at all times when candles are lit. When lighting candles inside Jack-O-Lanterns, use long, fireplace-style matches and be sure to place lit pumpkins well away from anything that can burn including doorsteps, walkways and yards. Dried flowers, cornstalks and crepe paper are highly flammable. Keep these and other decorations well away from all open flames and heat sources, including light bulbs, heaters, etc. The fake spider web material may also be flammable, but if purchased new, may now be found in nonflammable material.

Purchase only costumes, wigs and props labeled flame-resistant or flame-retardant. When creating a costume, choose material that won't easily ignite if it comes in contact with heat or flame. Avoid billowing or long trailing features. Use flashlights as alternatives to candles or torch lights when decorating. They are much safer for trick-or-treaters, whose costumes may brush against the lighting.

Instruct children to stay away from open flames or other heat sources. Be sure children know how to stop, drop and roll in the event their clothing catches fire. (Stop immediately, drop to the ground, covering your face with your hands, and roll over and over to extinguish flames.) And instruct children who are attending parties at others' homes or in public facilities to locate the exits and plan how they would get out in an emergency.

With a little common sense and an eye to the unexpected that can occur around open flames, you can enjoy your Halloween fun without fear.

Posted by Linda Chalat at 03:23 PM | Permalink | Comments (0) | TrackBacks (0)

From ghoulies and ghosties,
Long-leggety beasties,
And things that go bump in the night,
Good Lord, deliver us. - Anonymous

The ghouls and goblins will be out in just three short weeks – make sure your trick-or-treaters enjoy a safe and fun Halloween by reviewing these simple safety points.

Parents should establish and review Halloween safety rules with children for safe routes and houses, behavior, and other guidelines for a safe Halloween.

1. Make sure that an adult or an older responsible youth will be supervising the outing for children under age 12.
2. Plan and discuss the route trick-or-treaters intend to follow. The established route should only be in familiar areas.
3. Teach your children to stop only at houses or apartment buildings that are well-lit and never to enter a stranger's home.
4. Pin a slip of paper with the child's name, address, and phone number inside a pocket in case the youngster gets separated from the group.
5. Establish a return time and make sure children understand the importance of returning on time.
6. Everyone should carry a flashlight to see and be seen. Use fresh batteries.
7. Older children and escorts should wear a wristwatch and carry a mobile phone or coins for phone calls.
8. Tell your children not to eat any treat until they return home. All treats should be examined by an adult prior to eating.
9. Examine packaging of candy and other food items for evidence of tampering, such as pinholes in wrappers and torn wrappers. When in doubt about a treat, throw it out.
10. Wash fruit thoroughly, inspect it for holes and small punctures, and slice them into small pieces.
11. A good meal prior to parties and trick-or-treating will discourage children from filling up on Halloween treats.

Safe Halloween costumes and accessories are flame retardant, visible in the dark, and don't impede movement, breathing, or vision. Review these Halloween safety guidelines when purchasing or making costumes.

12. Look for the "Flame Resistant" label when purchasing costumes, masks, beards, and wigs. The label indicates the item will resist burning and should extinguish quickly once removed from the ignition source. However, this label does not mean the labeled items won't catch fire.
13. Avoid costumes made with flimsy materials and outfits with baggy sleeves or billowing skirts, to minimize the risk of contact with candles or other sources of ignition.
14. Purchase or make costumes that are light and bright enough to be clearly visible to motorists.
15. Decorate or trim costumes with reflective tape that will glow in the beam of a car's headlights. Bags or sacks should also be light colored or decorated with reflective tape.
16. Costumes should be short enough to prevent children from tripping and falling.
17. Children should wear well-fitting, sturdy shoes. Avoid high heels.
18. Apply a mask of non-toxic and hypoallergenic cosmetics rather than have a child wear a loose-fitting mask that might restrict breathing or obscure vision.
19. If a mask is used, make sure it fits securely, has eye holes large enough to allow full vision, and breathing holes large enough for full breathing.
20. Swords, knives, and similar costume accessories should be of soft and flexible material, with blunt edges and points. No sharp objects should be carried.

Make sure children understand the rules of a safe Halloween by discussing safe houses to visit, safe behavior, and what to do in an emergency.

21. Stay together as a group, and never be alone at any time.
22. Go only to homes where the residents are known and have outside lights on as a sign of welcome.
23. Do not enter homes, apartments, or cars without adult supervision.
24. Walk, do not run, from house to house. Do not run from between parked cars, or across lawns and yards where ornaments, furniture, or clotheslines present dangers.
25. Walk on the left side of the road, facing traffic. Use the sidewalk, not the street.
26. Do not eat any treats before an adult has carefully examined them for evidence of tampering.
27. Know your home phone number and how to call 911 (or local emergency number) if you have an emergency or become lost. 911 can be dialed free from any phone.
28. Use "Stop-Drop-Roll" should your clothes catch on fire.

Posted by Linda Chalat at 11:10 AM | Permalink | Comments (0) | TrackBacks (0)