The People of the State of New York, Appellant v. Michael Angelo, Respondent

Summary

The New York Court of Appeals affirmed the conviction for second-degree manslaughter, holding that the statutory term “culpable negligence” requires a degree of negligence beyond ordinary negligence and that the evidence supported such a finding. The Court explained the legislative intent and historical background of the term, rejecting the Appellate Division’s view that the jury instruction was erroneous.