PROCEDURAL POSTURE: Defendant appealed his conviction and sentence entered in a trial court (Massachusetts) for wanton and reckless conduct that resulted in manslaughter.
-Fire broke out in nightclub owned by defendant and many patrons and staff were killed or injured because there were inadequate, blocked, or locked exits.
-Defendant was indicted for manslaughter. Defendant filed motions to quash certain counts of the indictments, which were denied as to some and allowed as to others. Defendant was convicted and appealed his conviction.
The court concluded that the motions to quash certain counts were properly denied since defendant had the benefit of specifications that were as complete and detailed as required by fairness or the Constitution.
The court affirmed defendant's conviction for manslaughter. The court held that the prosecution was not required to prove that he caused the fire by some wanton or reckless conduct. A fire in a place of public resort was an ever-present danger. It was enough to prove that death resulted from defendant's wanton or reckless disregard of the safety of the patrons in event of a fire from any cause.
OUTCOME: The court affirmed defendant's conviction of manslaughter, holding prosecution was not required to prove he caused fire by some wanton or reckless conduct but that it was enough to prove that death resulted from his wanton or reckless disregard of safety of patrons in event of fire from any cause.