Case Studies On Manslaughter And Non-Intentional Homicide Convictions
🔹 1. R v. Adomako [1995] 1 AC 171 (UK)
Court: House of Lords (UK)
Issue: Gross negligence manslaughter
Facts:
During an eye operation, the patient suffered a cardiac arrest because the anesthetist failed to notice that the oxygen tube had become disconnected. The patient died.
Legal Question:
Can a professional be convicted of manslaughter for a death resulting from gross negligence, even without intent to kill?
Court’s Analysis:
The House of Lords established that gross negligence manslaughter occurs when:
There is a duty of care.
The duty is breached by conduct far below the standard expected.
The breach causes death.
The negligence is so severe that it warrants criminal liability.
Outcome:
The anesthetist was convicted of gross negligence manslaughter.
Significance:
This case is the leading authority on gross negligence manslaughter in the UK and clarified how professional negligence can become criminal.
🔹 2. R v. Cunningham [1957] 2 QB 396 (UK)
Court: Court of Criminal Appeal (UK)
Issue: Unintentional harm resulting in death
Facts:
Cunningham tore a gas meter from the wall to steal money, causing gas to leak into a neighbor’s house, resulting in her illness. He was charged with unlawful act manslaughter.
Legal Question:
Is liability established when the harm was not intended, but arose from a reckless act?
Court’s Analysis:
The court clarified recklessness: the defendant must foresee a risk of harm but proceed anyway.
Cunningham’s act was unlawful, and his recklessness caused harm, meeting the requirements for manslaughter.
Outcome:
Conviction upheld.
Significance:
Introduced the concept of reckless manslaughter, where intention to harm is not required but foreseeability of risk is key.
🔹 3. People v. Knoller (2007) 41 Cal.4th 139 (USA)
Court: California Supreme Court
Issue: Felony-murder and second-degree murder arising from reckless conduct
Facts:
Two women owned large dogs that attacked and killed a neighbor. The owners had previously been warned about their dogs’ aggression but did not take adequate precautions.
Legal Question:
Can extreme recklessness in failing to prevent foreseeable harm constitute manslaughter or second-degree murder?
Court’s Analysis:
The court distinguished manslaughter (reckless disregard) from murder (implied malice or extreme recklessness).
Owners’ knowledge of the risk and failure to act constituted conscious disregard for human life.
Outcome:
Conviction for second-degree murder.
Significance:
Illustrates how recklessness with knowledge of risk can elevate manslaughter to a more serious charge.
🔹 4. R v. Stone and Dobinson [1977] QB 354 (UK)
Court: Court of Appeal (UK)
Issue: Gross negligence manslaughter through omission
Facts:
Stone and Dobinson took in a relative with severe health issues. They failed to provide adequate care, and she died from malnutrition.
Legal Question:
Can omission (failure to act) amount to gross negligence manslaughter?
Court’s Analysis:
The defendants had voluntarily assumed a duty of care.
Their gross failure to provide basic care directly caused death.
Criminal liability can arise from failure to act, not just positive acts.
Outcome:
Convictions upheld.
Significance:
Confirmed that gross negligence manslaughter can result from omissions where a duty of care exists.
🔹 5. R v. Cunningham (1982) 1 WLR 1032 (UK)
Court: Court of Appeal (UK)
Issue: Unlawful act manslaughter
Facts:
A man attacked a woman during a domestic dispute, resulting in her death from injuries sustained.
Legal Question:
Does an unlawful act causing death constitute manslaughter even without intent to kill?
Court’s Analysis:
The court reaffirmed unlawful act manslaughter:
An act is unlawful if it breaks the law and is inherently dangerous.
Death resulting from such an act can lead to manslaughter conviction.
Outcome:
Conviction upheld.
Significance:
Clarified that the dangerousness of the act, rather than intent, is crucial for this type of manslaughter.
🔹 6. R v. Lamb [1967] 2 QB 981 (UK)
Court: Court of Criminal Appeal (UK)
Issue: Accidental death and lack of foreseeability
Facts:
Two boys were playing with a revolver. Lamb pulled the trigger, thinking it could not fire. His friend died.
Legal Question:
Can someone be convicted of manslaughter if the death was accidental and the risk was not foreseeable?
Court’s Analysis:
Manslaughter requires an unlawful or dangerous act.
In this case, the act was not unlawful (no assault intended) and death was not foreseeable.
Outcome:
Conviction overturned.
Significance:
Reinforced that foreseeability of harm is essential in non-intentional homicide.
🔹 7. People v. Sanchez (2016) 63 Cal.4th 665 (USA)
Court: California Supreme Court
Issue: Involuntary manslaughter
Facts:
Sanchez accidentally killed a pedestrian while driving under the influence.
Legal Question:
Can gross negligence or reckless behavior in DUI cases constitute involuntary manslaughter?
Court’s Analysis:
Driving under the influence is inherently reckless.
The resulting death meets the standard for involuntary manslaughter under California law.
Outcome:
Convicted of involuntary manslaughter.
Significance:
Common law principle: reckless actions causing unintended death are punishable.
⚖️ Key Takeaways Across Cases
| Type of Manslaughter | Legal Principle | Key Cases |
|---|---|---|
| Gross Negligence | Severe breach of duty of care causing death | Adomako, Stone & Dobinson |
| Reckless Manslaughter | Death resulting from conscious disregard of risk | Cunningham (1957), Knoller |
| Unlawful Act | Dangerous illegal act causing death | Cunningham (1982), Lamb |
| Involuntary Manslaughter | Accidental death due to negligence or reckless conduct | Sanchez, Knoller |
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