Frank R. Johnson, Petitioner v. State of Alaska, Respondent

Summary

The Alaska Supreme Court vacated the court of appeals' decision because its foreseeability standard for criminal liability based on reckless conduct did not expressly require consideration of whether the actual harm was too remote or accidental. The court held that the defendant need not foresee the precise manner of harm, but the general type of harm must be foreseeable, the actual harm must fall within the scope of the risk created by the conduct, and the harm must not be too remote or accidental. The court remanded without deciding whether a retrial would violate double-jeopardy principles.