United States v. Schmidt
United States Court of Appeals for the Eighth Circuit
626 F. 2d 616 (1980)
- Written by Rich Walter, JD
Facts
The federal government (plaintiff) prosecuted Clarence Frederick Schmidt (defendant) for involuntary manslaughter, in violation of 18 U.S.C. § 1112. The jury could infer from the somewhat contradictory trial evidence that Schmidt was intoxicated and speeding when he ignored a stop sign and drove into the path of Mark Van Heeder's car, crashing into the car and killing Van Heeder. There was also evidence that Schmidt knew his car's brakes were defective, and that just before the accident a passenger alerted Schmidt to Van Heeder's car and advised Schmidt to apply his emergency brake. The trial judge properly instructed the jury as to the law, and the jury returned a guilty verdict. Schmidt appealed to the Eighth Circuit Court of Appeals, contending that the evidence established at most that he acted with simple negligence, rather than with the gross negligence needed to sustain a conviction for involuntary manslaughter.
Rule of Law
Issue
Holding and Reasoning (Hanson, J.)
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