Introduction:-
They say lady Justice is blind because she is only informed by the provisions of the law despite the emotional aspects and particular circumstances of a case. The instant case provides a scenario where the people were so aggrieved by the circumstances of the case that they coveted extra-judicial solutions but instead, perhaps due to the tenets of civilization opted to stretch the law a little bit in pursuit of Justice. However, courts of law should only become courts of justice if the law and justice when the interests of justice tally with the relevant legal provisions.
Facts of the Case :-
The 1st Defendant is a manufacturing Company with the Co-Defendants being senior officials of the 1st Defendant who are directly involved in the management of its manufacturing arm. The cause of action was an explosion that took place in one of the Defendants’ manufacturing plants injuring over Fifty employee, six of the fatally. The explosion was ruled by an officer from the New York City Fire Marshal and an investigator for the United States Occupational Safety and Health Administration to be a combination of two explosions, one caused by a malfunction in a machine occasioned law temperature probably cause by peeling paint, and which triggered a second explosion, occasioned the injuries and fatalities as well as massive destruction to the Defendant’s plant.
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This second massive explosion made possible by the accumulation of Magnesium Stearate dust, which was a byproduct of the manufacture of chewing gum by the Defendant. It is also worthy of notice that prior to the incident, the 1st Defendant’s insurers had informed the 1st Defendant of the risks posed by the accumulation of Magnesium Stearate gas in the plant and advised the Defendant to remedy the situation whereupon the Defendants initiated efforts to remedy the situation and were in the process of the same when the explosion took place.
Case History :-
The Defendants were indicted for 2nd degree Manslaughter for negligently causing the death of the 6 employees who died in the explosion, the indictment was quashed by the Supreme Court who found in the favor of the Defendant. The People made an Appeal to the Appellate Division which found in favor of the People prompting the Defendants file the instant appeal to the Court of Appeals of the State of New York.
The Issue in Question :-
By the time the matter came before the Court of Appeals of the State of New York, all the factual matters had been ventilated and decided upon, the only issue before the Court was if the Defendants were criminally liable for Manslaughter for deaths occasioned by circumstances they were aware of despite the fact that the known circumstances were triggered by a factor independent of the facts already known to the Defendants, which factor the Defendants’ could not have reasonably expected.
Finding of the Court:-
The Court by a unanimous decision held in favor of the Defendants and found that for the Defendants to be criminally liable, they had to be aware of and negligent about the entire chain of causation that occasioned the act creating the cause of action. The court held that whereas there was previous holding regarding Defendants facing Manslaughter Charges for a manufacturing incident, the circumstances of the case mirrored in People v Kibbe (35 N.Y.2d 407 where the Defendants had left an intoxicated friend under circumstances where he could have frozen to death; however, a vehicle fatally hit the friend before he could freeze to death and the court found that the Defendants were not Criminally liable. In the same spirit, in the instant case the court found that the Defendants were not liable for Manslaughter despite their liability for negligence, albeit they would otherwise be liable under tort laws, seeing that there was no proof that they were negligent for the act that triggered the chain of event that occasioned the fatalities.
Conclusion: -
Thus Ruling was most definitely unfair to the People of New York but good for the Rule of Law. The Court was compelled to be a Court of Law as opposed to being a Court of Justice and therefore ruled correctly in the eyes of the Law. The onus of proof in Criminal Liability is on the threshold of beyond reasonable doubt as opposed to tort where it is on a balance of probabilities. Despite the fact that the Defendants really deserved punishment, the relevant provisions of the Law clearly vindicated them.
References :
People v. Warner-Lambert Co., 51 N.Y.2d 295, 414 N.E.2d 660, 434 N.Y.S.2d 159 (1980).
