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People v. Flayhart

New York Court of Appeals
72 N.Y.2d 737 (1988)


Facts

Richard and Beatrice Flayhart (defendants), who were married, lived with Richard’s brother, Terry Flayhart. Terry was mentally disabled, suffered from cerebral palsy and epilepsy, and was totally dependent on Richard’s and Beatrice’s care. Terry died of malnutrition and inflammation of the lungs, with pneumonia as a complicating factor. Terry had a $122,000 trust fund that had been established to pay for his care, but Terry had not seen his regular doctor during the previous two years. The State of New York (plaintiff) charged Richard and Beatrice with reckless manslaughter and criminally negligent homicide. The state presented the theory that Richard and Beatrice, acting together with the requisite culpable mental states, had engaged in conduct that caused the death of Terry. The trial court instructed the jury on criminally negligent homicide and reckless manslaughter and also instructed the jury on accomplice liability. The jury convicted Richard and Beatrice of criminally negligent homicide. Richard and Beatrice appealed, and the Appellate Division affirmed. Richard and Beatrice then petitioned the New York Court of Appeals for review.

Rule of Law

Issue

Holding and Reasoning (Titone, J.)

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