Why is the case important?
Defendant Jones was found guilty of involuntary manslaughter of his friend’s 10-month-old baby where he failed to provide for the child and such failure resulted in the child’s death.
Facts of the case
Was failure to instruct the jury that it must find beyond a reasonable doubt that Defendant was under a legal duty to provide for the child plain error?
Yes. Judgment reversed and remanded.
Omission of an act is only punishable where the duty neglected is a legal duty and not merely a moral obligation.
The court held that criminal liability could be found for breach of a statutory duty where there was a certain status relationship, where one had assumed a contractual duty, and where one had secluded a helpless person so as to prevent others from aiding. Thus, since a finding of legal duty was the critical element of the crime charged, failure to instruct the jury concerning it was plain error. Further, it was obvious error to instruct the jury without notice to counsel.
- Case Brief: 1960
- Petitioner: Jones
- Respondent: United States
- Decided by: Burger Court
Citation: 463 US 354 (1983)
Argued: Nov 2, 1982
Decided: Jun 29, 1983