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From what I've read, both of those individuals were misdiagnosed. Steven Thorpe, for example, was in a chemically induced coma, and you cannot really declare someone brain dead when they're in a chemically induced coma (why would he even be in a chemically induced coma if he was brain dead?). According to media reports, his CT scans showed "almost irreversible" injury, which is not the same as brain death, since someone can survive an irreversible injury. Also, it does happen occasionally that people recover from traumatic brain injuries (like Steven Thorpe's, which was the result of car accident), but usually not in victims of brain injury due to lack of oxygen or blood flow in the brain (e.g. heart attack victims like Jahi). And no one who has ever met ALL the criteria for brain death (like Jahi does and Steven Thorpe did not) has ever woken up.