People v. Warner-Lambert Co.
Court of Appeals of New York
51 N.Y.2d 295 (1980)
At a Warner-Lambert Co. (defendant) chewing-gum factory, a buildup of magnesium stearate dust near a Uniplast machine, combined with liquid nitrogen used in production, led to a catastrophic explosion and fire that killed six workers and injured more than fifty; the company and four corporate officials were charged with second-degree manslaughter and criminally negligent homicide. The prosecution offered two competing, largely speculative theories for what actually ignited the explosion -- a mechanical spark or a liquid-nitrogen-to-liquid-oxygen reaction -- without solid proof that either specific mechanism was foreseeable to the defendants. The trial court dismissed the indictment, the appellate division reversed, and the defendants appealed.
Whether the standard of negligence sufficient for criminal homicide liability requires a different type and greater amount of proof than the standard sufficient for civil tort liability.