Connecticut v. White

White (defendant) failed to install smoke detectors in one of his two residential buildings, where a fire later killed residents on the second floor from smoke inhalation; a 1976 statutory amendment required the fire marshal to "include" a smoke-detector requirement in the fire safety code for certain residential buildings receiving building permits on or after October 1, 1976, and the fire marshal adopted a code section requiring detectors without limiting it to buildings permitted after that date. The state charged White criminally for the missing detectors, and after conviction, White argued the code exceeded the fire marshal's delegated authority.