Facts: On February 10, 1983, Stefan Golab, a worker at Film Recovery, fell ill while performing his duties. He was rushed to the hospital after losing consciousness and foaming at the mouth. Upon arrival at the hospital, however, he was pronounced dead and an autopsy was performed to determine the cause of his death. The autopsy results indicated that Golab had died of acute cyanide poisoning that he had inhaled while working at the company’s plant. The defendant, Steven O’Neil who was a senior manager at the company was charged with murder together with two fellow managers. The grand jury argued that as senior officials at the company, the three individuals had knowingly created an environment that led to Golab’s death by failing to advise and train him on the dangerous chemicals and provide him with protective equipment. Likewise, the company, Film Recovery, and her sister company, Metallic Marketing, were charged with involuntary manslaughter. The argument was that the companies had unintentionally murdered Golab through the negligent acts of their directors. In addition to the murder and involuntary manslaughter charges, the jury also charged the individual and corporate defendants with reckless conduct.
Issue: Two issues were raised by the individual defendants. First, O’Neil and his colleagues argued that murder and reckless conduct require different mental states in that for the former to occur, it must be both knowingly and intentional while the former occurs unintentionally. An act therefore cannot be murder and reckless conduct at the same time, hence the inconsistency in the charges. Secondly, the defendants argued that the murder charges were inconsistent with the involuntary manslaughter charge against the corporate defendants.
Holding: It was held that the charges made against the defendants were inconsistent. It was also held that the charges against the individual defendants do not provide the basis upon which criminal responsibility can be established against the corporate defendants.
Reasoning: The court argued that murder is committed when a person kills another knowingly and intentionally without any lawful reason to justify his actions. On the other hand, manslaughter is committed when a person kills another person unintentionally without any lawful reason to justify his actions. These two actions, therefore, require different mental states. Reckless conduct is any act that leads to the death or grave bodily harm to another person resulting from reckless behavior. Because the charges made against the defendants are based on one event, their actions could not have been intentional and unintentional at the same time and therefore the charges are not legally consistent.
In Illinois, a corporation has criminal responsibility for acts committed by its directors and other high managerial officers working within the limits of their employment and having the necessary mental state. Based on the testimony presented, the court was unable to relate the charges made against the individual defendants with those made against the corporate defendants.
Rule: The holding and reasoning of this case were based on the Criminal Code of 1961 which clearly defines and distinguishes murder, involuntary manslaughter, and reckless conduct. They were also governed by the Illinois criminal statutes which clearly define corporate criminal responsibility.
Concurring: Judge Lorenz agreed with the holding presented by the court by arguing that the charges made against the defendants were indeed inconsistent.
Dissenting: There are no dissenting judges.
References
Findlaw.com. People v. O’Neil, 550 N.E.2d 1090 (1990). Web.