State v. Biechele

Daniel Biechele (defendant), a band's tour manager, ignited pyrotechnics inside a Rhode Island nightclub during a show; the resulting fire killed 100 people. The State of Rhode Island (plaintiff) charged Biechele with 100 counts of misdemeanor manslaughter, based on the theory that his unlicensed possession and use of fireworks -- itself a misdemeanor -- caused the deaths. Biechele moved to dismiss, arguing the underlying misdemeanor for a misdemeanor-manslaughter charge must be malum in se (inherently wrongful) rather than malum prohibitum (wrongful only because prohibited), and that the charge violated due process because it carried no required mental state.