Case Name: People v. Warner-Lambert Co.
Citation: 51 N.Y.2d 295 (1980)
Facts: Warner-Lambert Co. and its officers/employees were indicted for second-degree manslaughter and criminally negligent homicide. A massive explosion at the corporation’s chewing-gum factory killed and injured employees. Warner-Lambert Co. used two potentially explosive substances (magnesium stearate and liquid nitrogen) and had been warned by their insurance carrier that there was an explosion harzard.
Defendant’s argument: There was no hard proof on what actually triggered the explosion but only speculations by experts that it could have been caused by the manufacturing process. Therefore, foreseeability was not established.
State’s argument: The but-for causation is all that is required for the imposition of criminal liability. There was evidence of a foreseen risk of explosion, the defendant’s failure to remove the risk, and an explosion actually occurring.
Holding: Indictment dismissed.
Reasoning: The defendants’ actions must be a sufficiently direct cause of the ensuing death before there can be any imposition of criminal liability. The court focuses on whether there was an actual cause. You must find the “actual cause” before you can establish “foreseeability.”
Compare to People v. Arzon