People v. Warner-Lambert Co. case brief
51 N.Y.2d 295
PROCEDURAL POSTURE: Defendants, a corporation and its officers, appealed a decision from the Appellate Division of the Supreme Court in the Second Judicial Department (New York), which reversed the dismissal of an indictment. The dismissal was on the grounds that the evidence before the grand jury was not legally sufficient to establish the offenses charged or any lesser-included offenses.
OVERVIEW: Defendant corporation and its officers were charged with manslaughter and negligent homicide arising out of an explosion and fire at one of their facilities in which six employees died. Although there was evidence of a highly flammable chemical in the air and on the equipment, there was no proof of what triggered the explosion.
HOLDING:
On appeal, the court found no proof sufficient to support a finding that defendants foresaw or should have foreseen the physical cause of the explosion.
ANALYSIS:
Since the standard in a criminal case was higher than that in a tort claim, there was no legally sufficient evidence to establish the offenses charged or any lesser included offense.
OUTCOME: The court reversed the decision and dismissed the indictment as there was no legally sufficient evidence that the triggering event of the explosion, which resulted in the death of the employees, was foreseeable.
51 N.Y.2d 295
PROCEDURAL POSTURE: Defendants, a corporation and its officers, appealed a decision from the Appellate Division of the Supreme Court in the Second Judicial Department (New York), which reversed the dismissal of an indictment. The dismissal was on the grounds that the evidence before the grand jury was not legally sufficient to establish the offenses charged or any lesser-included offenses.
OVERVIEW: Defendant corporation and its officers were charged with manslaughter and negligent homicide arising out of an explosion and fire at one of their facilities in which six employees died. Although there was evidence of a highly flammable chemical in the air and on the equipment, there was no proof of what triggered the explosion.
HOLDING:
On appeal, the court found no proof sufficient to support a finding that defendants foresaw or should have foreseen the physical cause of the explosion.
ANALYSIS:
Since the standard in a criminal case was higher than that in a tort claim, there was no legally sufficient evidence to establish the offenses charged or any lesser included offense.
OUTCOME: The court reversed the decision and dismissed the indictment as there was no legally sufficient evidence that the triggering event of the explosion, which resulted in the death of the employees, was foreseeable.
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