Methlab Fire results in Manslaughter Conviction - Upheld
Methlab Fire results in Manslaughter Conviction - Upheld
This case is on appeal from "a verdict convicting defendant of the crimes of manslaughter in the second degree and unlawful manufacture of methamphetamine in the third degree." The Defendant was in the crystal meth business - the manufacturing of the product. "[T]hey placed three plastic pitchers containing lantern fuel on a lit wood-burning stove. The fuel ignited, causing a fire that burned the cabin to the ground. While all four of the cabin's occupants exited the building, the victim later died in the hospital as a result of severe burns covering the majority of her body." Thereafter, the Defendant (Peters) was charged with the crimes of which he was later convicted. While conceding that it was reckless, Defendant asserts that the evidence was not legally sufficient for the jury verdict.
Legal Standard: [In conducting a legal sufficiency review, "we view the evidence in the light most favorable to the People and will not disturb the verdict so long as the evidence demonstrates a valid line of reasoning and permissible inferences that could lead a rational person to the conclusion reached by the jury" (People v. Peryea, 68 AD3d 1144, 1146 [2009], lv denied 14 NY3d 804 [2010] [citations omitted]; see People v. Bleakley, 69 NY2d 490, 495 [1987]; People v. Barreto, 64 AD3d 1046, 1048 [2009], lv denied 13 NY3d 834 [2009]). "A person is guilty of manslaughter in the second degree when [he or she] recklessly causes the death of another person" (Penal Law §125.15 [1]; see People v. Heslop, 48 AD3d 190, 195 [2007], lv denied 10 NY3d 935 [2008]). Recklessness in this context requires that a person be "aware of and consciously disregard[] a substantial and unjustifiable risk" of death (Penal Law §15.05 [3]; see People v. Hartman, 4 AD3d 22, 24 [2004]).]
The evidence adduced at trial was fascinating. In their goal of producing this drug, the drug manufacturers placed this fuel on the stove and became preoccupied with something else. After realizing that the fuel was on the stove for "too long," there was an attempt to remove the fuel, the pitcher melted and the cabin was consumed by the fire produced by this fiasco. At trial, "an arson investigator with the State Office of Fire Prevention and Control testified that lantern fuel can ignite without an open flame and that, following the fire, the wood stove was found with the residue of melted plastic on its surface. Additionally, a hazardous materials specialist with the same state office testified that a wood stove could heat a plastic pitcher to melting temperature."
Because the Defendant conceded that he knew the risk associated with the activity, that being plastic pitchers would obviously melt if placed on a hot plate and he was aware of the commonplace explosion of methlabs, the Court upholds the manslaughter verdict. Affirmed.
The Case is People v. Brion L. Peters, 105064, NYLJ 1202719840029, at *1 (App. Div., 3rd, Decided March 5, 2015)
