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People v Decina
Ct. App. New York, 1956
Author:- Sam Biers
Facts: Df suffered from epileptic seizures. While driving his Buick he had an attack, which caused the car “to travel at a fast and reckless rate of speed, jumping the curb and drinving over the sidewalk,” killing 4 people.
Issue: Whether a person who suffers a known medical condition while driving a car and causes death, can be criminally liable?
Holding: Yes
Procedure: Df was convicted of Cirminal negligence in the operation of a vehicle causing death. App Division reversed in part(incompetent testimony) and ordered a new trial. DF and People appealed. Affirmed.
Rule: Df’s conduct manifested a disregard of the consequences which may ensue from the act, and an indifference to the rights of others.
Ct Rationale: Intent- knowledge of a condition that would seriously impair and consciously driving the vehicle which caused the death of another would result in a charge of murder. Df did not deliberately intend to kill a human being. Df knew he was subject to attacks that might strike at any time. He also knew that an uncontrolled motor vehicle on a public highway is a dangerous instrument capable of unrestrained destruction. With this knowledge he deliberately took the chance, by consciously choosing a course of action, in disregard of the consequences.
PL A: The Df knew that he had a condition that created a situation resulting in death, which he ignored.
Def A: The indictment does not charge a crime, if Df is unconscious he cannot knowingly act. Df did not intend to kill anyone.