State v. Sealy
Supreme Court of North Carolina
117 S.E.2d 793 (1961)
Howard Franklin Sealy (defendant) failed to stop at a stop sign while driving and struck and killed two men; he was charged with involuntary manslaughter. At trial, the judge gave the jury two instructions the State later conceded were in conflict: one stating the jury must convict if it found Sealy intentionally violated safety statutes designed to protect human life and that violation proximately caused the deaths, and another stating the jury should convict simply if it found Sealy was operating in violation of the stop-sign statute and that violation proximately caused the deaths—without requiring intentional or reckless conduct. Sealy was convicted and appealed, arguing the conflicting instructions constituted reversible error.
Whether, to impute criminal culpability to a defendant, an unintentional or inadvertent violation of a statute must be accompanied by recklessness amounting to a thoughtless disregard of dangerous consequences to others.