What is “Involuntary Manslaughter” in Maryland?

Manslaughter is a homicide that occurs without premeditation. Manslaughter can either be voluntary or involuntary. Voluntary manslaughter means someone willfully kills another person without premeditation. Involuntary manslaughter, in contrast, means the killing was neither intentional nor premeditated.

Involuntary manslaughter is still a crime in Maryland. The law broadly recognizes three types of involuntary manslaughter:

• Unlawful act manslaughter – This is when someone commits an illegal act that endangers life but that act is not a felony in and of itself.
• Gross negligence manslaughter – Negligently committing an otherwise lawful act that causes someone’s death.
• Negligent omission manslaughter – The failure to perform a legal duty that results in death.

Court of Appeals Upholds Conviction of Homeowner Following Fatal House Fire

The Maryland Court of Appeals recently upheld an involuntary manslaughter conviction based on gross negligence and negligent omission. In State v. Beckwitt, the victim was an aspiring software developer looking to market a smartphone app. The defendant invested $10,000 in the project. When the victim failed to secure a fellowship, he agreed to repay the defendant by digging tunnels underneath the defendant’s house. (The defendant apparently wanted to build a bunker due to fear of nuclear war with North Korea.)

One day while working in the basement, the victim texted the defendant that there was no power. Shortly thereafter, the victim reported there was smoke. Several hours passed. The defendant went downstairs and noticed his refrigerator was not working. After waiting another 20 to 30 minutes, he went to the basement to reset the circuit breaker. While leaving the basement, the defendant said he heard an explosion. He then saw smoke coming up into the kitchen and realized there was a fire. The defendant said he yelled at the victim to get out of the basement.

Neighbors called the local fire department. Firefighters said they “struggled to navigate” inside the house due to the “extreme amount of debris, trash, and other objects” left inside. Eventually, the firefighters found the body of the victim.

Prosecutors charged the defendant with involuntary manslaughter. A jury found the defendant guilty. The Court of Special Appeals upheld the conviction, holding the evidence was sufficient to establish the defendant’s guilt for involuntary manslaughter based on gross negligence. Before the Court of Appeals, the defendant argued that under old English common law, a homeowner could not be held criminally responsible for an “accidental house fire.” The Court of Appeals held that was not a valid affirmative defense.

More to the point, the Court of Appeals agreed with the two lower courts that the evidence was sufficient to prove negligence by gross manslaughter. Alternatively, since the defendant was the victim’s employer at the time of the fire, the evidence also supported a guilty verdict of gross manslaughter based on the defendant’s failure to perform a legal duty to maintain a safe workplace.

Contact Prince George’s County, Maryland, Criminal Defense Lawyer Robert Castro Today

This article has been provided by the Law Office of Robert Castro. For more information or questions contact our office to speak to an experienced lawyer at (301) 705-5137.

Source:

https://www.courts.state.md.us/data/opinions/coa/2022/16a21.pdf