People v Beardsley

150 Mich. 206, 113 N.W. 1128 (1907)



Under some circumstances the omission of a duty owed by one individual to another, where such omission results in the death of the one to whom the duty is owing, will make the other chargeable with manslaughter. This rule of law is always based upon the proposition that the duty neglected must be a legal duty, and not a mere moral obligation. It must be a duty imposed by law or by contract, and the omission to perform the duty must be the immediate and direct cause of death.


A married man was having an affair with a woman. In his presence, she overdosed on morphine. He was intoxicated at the time and arranged for an acquaintance to take the woman to another room in the house. The woman subsequently died, and the man was convicted of manslaughter in Circuit Court for Oakland County. The case was appealed to the Supreme Court of Michigan.


Was the conviction of manslaughter proper?




The Court reversed the decision, holding that the accused had no legal duty to the woman to take reasonable measures to prevent her death. The court rejected the prosecutor's argument that respondent assumed the role of natural guardian and protector, which gave rise to a legal duty to make reasonable efforts to save her life. The court stated that although respondent's conduct may have been morally reprehensible, respondent did not have a legal duty to the woman simply because she was in his house. Because no legal duty existed and because respondent was not an active agent in causing woman's death, the court held that no criminal liability attached.

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