People v. Warner-Lambert Co.

51 N.Y.2d 295, 434 N.Y.S.2d 159, 414 N.E.2d 660 (1980)



The evidence must be viewed in the light most favorable to the People, when considering a motion to dismiss an indictment, and it may be legally sufficient although it does not even provide "reasonable cause" to believe that the defendant committed the crime charged, N.Y. Crim. Proc. Law § 70.10.


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. The trial court dismissed the case on the grounds that the evidence before the grand jury was not legally sufficient to establish the offenses charged or any lesser-included offenses. The Appellate Division of the Supreme Court in the Second Judicial Department (New York), however, reversed the dismissal of an indictment. The case was appealed to the Court of Appeals of New York.


Should the indictment be dismissed?




The court found no proof sufficient to support a finding that defendants foresaw or should have foreseen the physical cause of the explosion. Since the standard in a criminal case was higher than that in a tort claim, the Court held that there was no legally sufficient evidence to establish the offenses charged or any lesser included offense.

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