People v. Steinberg

79 N.Y.2d 673 (1992)

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People v. Steinberg

New York Court of Appeals
79 N.Y.2d 673 (1992)

  • Written by Haley Gintis, JD

Facts

Joel Steinberg (defendant) and Hedda Nussbaum adopted a child, Lisa. On November 1, 1987, Steinberg was in the bedroom getting ready for a dinner appointment when six-year-old Lisa entered the bedroom. Shortly after, Steinberg left the bedroom carrying Lisa, who was unconscious. Steinberg told Nussbaum that he had knocked Lisa down. Nussbaum tried to revive Lisa while Steinberg continued to get ready. Steinberg left for dinner and told Nussbaum to let Lisa sleep. Early the next morning, Steinberg began trying to resuscitate Lisa, but she was no longer breathing. Steinberg eventually called an ambulance to transport Lisa to the hospital. At the hospital, doctors determined that Lisa was comatose because of severe head injuries. Lisa was declared brain dead, and life support was discontinued. The State of New York (plaintiff) prosecuted Steinberg for Lisa’s death. At trial, Nussbaum testified that Steinberg was with Lisa at the time of the assault and had admitted to knocking Lisa down. Nussbaum also testified that Steinberg believed that Lisa and her brother were trying to put him in a hypnotic state. Evidence was introduced to show that the Lisa’s injuries were caused by a man of Steinberg’s stature, and that Steinberg had bruises on his hands from the assault. Steinberg was convicted of first-degree manslaughter. The conviction was appealed. On appeal, Steinberg argued that his failure to obtain medical care for Lisa did not meet the required mens rea for manslaughter. Steinberg alleged that because he did not have any medical knowledge, he could not be expected to know that withholding medical treatment would result in serious injury to Lisa. Steinberg also argued that the state’s evidence was not legally sufficient to establish first-degree manslaughter. The appellate division affirmed the conviction. The matter was appealed again.

Rule of Law

Issue

Holding and Reasoning (Kaye, J.)

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