People v. Beardsley

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People v. Beardsley
Supreme Court of Michigan, 1907
Author: Secret Helper

Facts: Defendant and the deceased (a woman) had drunk alcohol together on previous occasion and on the day the deceased died, the defendant and the deceased were drinking heavily. The deceased took some morphine pills and passed out. The defendant told a young man to take the deceased to a room and then send her home when she wakes up. The woman never woke up and she turned out to be dead.

Rule: “…under some circumstances the omission of 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...If a person who sustains to another the legal relation of protector, as husband to wife, parent to child, master to seaman, etc., knowing such person to be in peril of life, willfully or negligently fails to make such reasonable and proper efforts to rescue him as he might have done without jeopardizing his own life or the lives of others, he is guilty of manslaughter at least…”

Procedure: The defendant was convicted of manslaughter.

Issue:Did the defendant have a legal duty towards the deceased at the tome of her death?

Holding: No

Rationale: The deceased had been involved in drinking on prior occasions with the defendant. “Her entire conduct indicates that she had ample experience in such affairs.” Just because the deceased was a woman doesn’t mean that the defendant owed her the duty of a husband-wife relationship. Yes the defendant had moral obligation to protect the deceased, but he did not have the legal obligation. Conviction set aside.

4 situations in which failure to act constitute breach of legal duty:

1. statute imposes the duty

2. where one stands in a certain status relationship to another

3. where one has assumed a contractual duty to care for another

4. where one has voluntarily assumed the care of another and secluded the helpless person from the possible aid of others.

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