United States v. Escamilla
United States Court of Appeals for the Fourth Circuit
467 F.2d 341 (1972)
Mario Jaime Escamilla (defendant) worked on a small research team on an isolated Arctic ice island. A rifle he was holding discharged without anyone pulling the trigger, striking and killing intoxicated coworker Bennie Lightsey, who had come to Escamilla's trailer looking for alcohol. No witnesses saw the actual shooting, but significant evidence showed the rifle had an unforeseeable defect that let it fire without a trigger pull, and that Escamilla did not know about this defect. He was convicted of involuntary manslaughter and appealed.
Whether an involuntary-manslaughter conviction requires proof beyond a reasonable doubt that the defendant's conduct was grossly negligent and that he had actual knowledge, or that it was reasonably foreseeable, that his conduct was a threat to others' lives.