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Case Law Database

Access over workers' compensation decisions, including En Banc, Significant Panel Decisions, and writ-denied cases.

Case No. MISSING
Regular Panel Decision
Nov 21, 1983

People v. Balls

The defendant, charged with manslaughter in the second degree, was convicted of criminally negligent homicide for the death of his seven-week-old daughter. The primary issue on appeal was whether the prosecutor's summation comments regarding the defendant's prearrest silence constituted reversible error. The court found these comments to be a permissible 'response in kind' to the defense's characterization of the defendant's behavior and deemed them harmless error, citing overwhelming evidence of guilt, including medical testimony of a comminuted skull fracture. The judgment was affirmed, and the imposed sentence of 1 1/3 to 4 years imprisonment was upheld.

Criminally Negligent HomicideManslaughter Second DegreeInfant DeathFractured SkullCircumstantial EvidenceProsecutorial MisconductPre-arrest SilenceHarmless ErrorSufficiency of EvidenceMedical Expert Testimony
References
15
Case No. E2003-00053-CCA-R3-CD
Regular Panel Decision
Nov 07, 2003

State of Tennessee v. Tammy Hart

Defendant Tammy Hart was indicted and convicted in Johnson County Criminal Court for child endangerment, vehicular homicide, and aggravated vehicular homicide following a head-on collision that resulted in a fatality. The trial court merged the vehicular homicide conviction into the aggravated vehicular homicide conviction and sentenced Hart to consecutive terms. On direct appeal to the Court of Criminal Appeals of Tennessee at Knoxville, Hart raised four issues: the denial of her motion to suppress medical records, the admission of those records into evidence, a violation of her constitutional right to confrontation, and the insufficiency of evidence to sustain her convictions. The appellate court affirmed the trial court's judgments, concluding that the State did not violate Hart's Fourth Amendment rights in subpoenaing her medical records, the records were admissible as business records, her confrontation rights were not violated due to waiver and ample cross-examination opportunities, and sufficient evidence supported the aggravated vehicular homicide and child endangerment convictions, citing her intoxication and prior DUI history.

Child EndangermentVehicular HomicideAggravated Vehicular HomicideDUIIntoxicationMedical RecordsSuppression MotionFourth AmendmentRight to ConfrontationSufficiency of Evidence
References
34
Case No. 339-83
Regular Panel Decision
Sep 16, 1987

VAUGHAN AND SONS INC. v. State

The case involves Vaughan and Sons, Inc., appealing its conviction for criminally negligent homicide, stemming from a motor vehicle collision allegedly caused by its agents, resulting in two deaths. The trial court fined the corporation $5,000. The Court of Appeals had reversed the conviction, asserting that corporate criminal liability for homicide was not intended by the penal code. However, the Court of Criminal Appeals of Texas, after reviewing the history of corporate criminal liability in Texas and legislative changes, including the broad definition of 'person' to encompass corporations, concluded that corporations can indeed be prosecuted for criminally negligent homicide under the relevant penal code sections. The Court reversed the Court of Appeals' judgment and remanded the case for further proceedings. A dissenting opinion by Judge Teague highlighted concerns about the constitutionality and implications of strict, automatic corporate criminal liability for employee negligence.

Corporate Criminal LiabilityCriminally Negligent HomicideStatutory InterpretationPenal CodeTexas LawCorporate PersonhoodLegislative IntentDue ProcessStrict LiabilityRespondeat Superior
References
60
Case No. MISSING
Regular Panel Decision
Dec 01, 1987

People v. Gaines

The Supreme Court, New York County, affirmed a judgment convicting the defendant of third-degree robbery. The defendant had entered a grocery store, threatened the cashier with what appeared to be a hand grenade, and claimed to have committed a homicide, stealing $15 before fleeing. He was later apprehended, and the inoperable grenade was recovered. The court ruled that the homicide threat merely enhanced the seriousness of the robbery threat, not constituting evidence of an uncharged crime. Additionally, the defendant's claim regarding courtroom closure during summation was not preserved for appellate review.

RobberyThird Degree RobberySecond Felony OffenderHand Grenade ThreatUncharged Crime EvidenceAppellate ReviewCourtroom ClosureCriminal Procedure LawAffirmance
References
2
Case No. MISSING
Regular Panel Decision

In the Matter of the Extradition of Vargas

The United States Government, on behalf of the Mexican Government, sought the extradition of Luis Castaneda Vargas for an alleged homicide in Nuevo Laredo, Tamaulipas, Mexico. Magistrate Judge J. Scott Hacker presided over the extradition hearing in the Southern District of Texas. The court found that all requirements for extradition were met, including jurisdiction, the existence of a valid extradition treaty between the U.S. and Mexico, dual criminality of the offense, and probable cause for the homicide charge. Despite Vargas's arguments challenging probable cause and claiming overcharging, the court granted the extradition request, certifying him as extraditable to Mexico.

ExtraditionHomicideMexicoProbable CauseTreatyDual CriminalityEyewitness TestimonyJudicial ReviewInternational LawFifth Circuit
References
50
Case No. 04-19-00737-CR, 04-19-00738-CR
Regular Panel Decision
Apr 27, 2022

Aidan Vitela v. the State of Texas

Aidan Vitela appealed his convictions for criminally negligent homicide and aggravated assault stemming from a fatal car crash. He challenged the trial court's denial of his motion to suppress 'black box' event data recorder evidence, the admission of the State's expert testimony, and the legal sufficiency of the evidence for criminally negligent homicide. The Fourth Court of Appeals in San Antonio affirmed the trial court's judgment. The appellate court found that Vitela lacked standing to challenge the black box evidence due to abandonment of his vehicle and upheld the admissibility of expert testimony. It further concluded that the evidence was legally sufficient to support the conviction and that any prosecutorial misconduct during closing arguments was effectively cured by the trial court's instructions.

Criminal Negligent HomicideAggravated AssaultFourth AmendmentMotion to SuppressBlack Box EvidenceExpert TestimonyDaubert StandardLegal SufficiencyProsecutorial MisconductJury Instruction
References
47
Case No. 2025 NY Slip Op 06622 [243 AD3d 923]
Regular Panel Decision
Nov 26, 2025

People v. Jia Xi Liu

This case concerns an appeal by Jia Xi Liu from a judgment convicting him of several offenses, including criminally negligent homicide and criminal possession of a forged instrument in the third degree, following a nonjury trial. The Supreme Court, Kings County, had sentenced him, as a second felony offender, to various terms of imprisonment. The Appellate Division affirmed the conviction for criminally negligent homicide, finding the evidence legally sufficient and the verdict not against the weight of the evidence. However, the court identified an illegal sentence for criminal possession of a forged instrument in the third degree, as a class A misdemeanor received an indeterminate term of imprisonment of 1 1/2 to 3 years, exceeding the statutory maximum of one year. Consequently, the judgment was modified by vacating that specific sentence, and the matter was remitted to the Supreme Court for resentencing on that conviction.

Criminally Negligent HomicideCriminal MischiefFalse InstrumentFraudulent PracticesWorkers' Compensation FraudTax FraudForged InstrumentIllegal SentenceResentencingAppellate Review
References
7
Case No. 2022 NY Slip Op 04195 [206 AD3d 1463]
Regular Panel Decision
Jun 30, 2022

People v. Faucett

On March 13, 2019, Lawrence E. Faucett, driving a tractor trailer, struck a Department of Transportation pickup truck operated by Dennis "Matt" Howe, who was alerting motorists to roadwork. Howe died five days later from his injuries. Faucett was subsequently convicted of criminally negligent homicide. On appeal, Faucett argued the verdict lacked legally sufficient evidence, specifically proof of blameworthy conduct beyond a failure to perceive and marginally exceeding the speed limit. The Appellate Division, Third Department, agreed, finding that an unexplained failure to see another vehicle, without more, does not support a conviction for criminally negligent homicide. The court also held that travelling marginally over the speed limit and failing to maintain a lane did not constitute the moral blameworthiness required. Consequently, the judgment of conviction was reversed, and the indictment dismissed.

Criminally Negligent HomicideLegal SufficiencyBlameworthy ConductFailure to Perceive RiskTraffic AccidentMotor Vehicle FatalityAppellate ReviewIndictment DismissalGross Deviation StandardCriminal Negligence
References
7
Case No. MISSING
Regular Panel Decision

Rothenberg v. AAA Custom Lab

This case involves an appeal from the Workers’ Compensation Board's decisions which determined that a decedent's death arose out of and in the course of his employment. The decedent, a vice-president of AAA Custom Lab, was fatally shot near a diner after a reported business meeting. The appellate court affirmed the Board's findings, concluding there was substantial evidence to support the decisions. A dissenting judge argued for remittal, citing concerns about potential involvement in an illegal enterprise and insufficient exploration of the meeting's nature and its link to the homicide.

Workers' CompensationEmployment InjuryHomicideBusiness MeetingAppellate ReviewAffirmationDissenting OpinionCausal ConnectionCourse of EmploymentArising Out Of Employment
References
2
Case No. 2020 NY Slip Op 00977 [180 AD3d 466]
Regular Panel Decision
Feb 11, 2020

People v. Cueva

The Appellate Division, First Department, affirmed the judgment convicting defendant Wilmer Cueva of criminally negligent homicide and reckless endangerment. Cueva, a construction foreman, was found to have personally ordered unsafe actions resulting in a fatal trench collapse. The court rejected the defendant's unpreserved legal insufficiency claim and found the verdict supported by overwhelming evidence. Furthermore, the court found no error in the jury instructions, the admission of gruesome autopsy photos, or the denial of defendant's motion to suppress his statements.

criminally negligent homicidereckless endangermenttrench collapse fatalityconstruction safety violationsforeman liabilityappellate affirmationsufficiency of evidencejury instruction reviewautopsy photo admissibilitysuppression motion
References
5
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