gross deviation standard (Maryland) · Go Syfert
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gross deviation standard in Maryland

8 Maryland opinions name it 2 courts 1991–2022 2 in the last five years

The cases below were cited by Maryland courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (5)

CaseFollowedCited
State v. FAR WEST WATER & SEWER INC.green
arizctapp · 2010 · cited in 1 Maryland opinions naming this issue, 2022–2022
1 sentence

2022Water & Sewer Inc., 228 P.3d 909, 927-29 (Ariz. Ct. App. 2010) (The Court of Appeals of Arizona held that the evidence was sufficient to support a corporation’s convictions for negligent homicide where a jury could reasonably conclude that management was “aware of the substantial and unjustifiable risk of death or physical injury involved in working in” the sewage treatment plant and consciously disregarded that risk, and that management’s conduct “constituted a gross deviation from the standard of care or conduct under a reasonable person standard[.]”).

11
State v. Randolgreen
kan · 1979 · cited in 1 Maryland opinions naming this issue, 2014–2014
2 sentences

2014In Butler, 880 S.W.2d at 397 , the court stated that the statutory definition of criminal negligence related to “(1) the defendant’s conduct, (2) a substantial and justifiable risk existing at the time of the conduct or resulting from the conduct, (3) the defendant’s failure ... to perceive the risk, and (4) that failure being a gross deviation from the standard of care.” 7 *683 Under those circumstances, the court held that “the statutory definition provides adequate notice of what conduct is covered.” In State v. Randol, 226 Kan. 347 , 597 P.2d 672, 673 (1979), the Kansas Supreme Court addre

2014In Butler, 880 S.W.2d at 397 , the court stated that the statutory definition of criminal negligence related to “(1) the defendant’s conduct, (2) a substantial and justifiable risk existing at the time of the conduct or resulting from the conduct, (3) the defendant’s failure ... to perceive the risk, and (4) that failure being a gross deviation from the standard of care.” 7 *683 Under those circumstances, the court held that “the statutory definition provides adequate notice of what conduct is covered.” In State v. Randol, 226 Kan. 347 , 597 P.2d 672, 673 (1979), the Kansas Supreme Court addre

11
Ball v. Stategreen
md · 1997 · cited in 1 Maryland opinions naming this issue, 1998–1998
2 sentences

1998See Maryland Rule 4-325(e)(“The court may, and at the request of any party shall, instruct the jury as to the applicable law and the extent to which the instructions are binding.”); Lansdowne v. State, 287 Md. 232, 239 , 412 A.2d 88, 91 (1980)(holding that the trial judge must “give a requested instruction which correctly states the applicable law and which has not been fairly covered in instructions”); cf. Ball v. State, 347 Md. 156, 190 , 699 A.2d 1170, 1186 (1997)(observing that Md.

1998See Maryland Rule 4-325(e)(“The court may, and at the request of any party shall, instruct the jury as to the applicable law and the extent to which the instructions are binding.”); Lansdowne v. State, 287 Md. 232, 239 , 412 A.2d 88, 91 (1980)(holding that the trial judge must “give a requested instruction which correctly states the applicable law and which has not been fairly covered in instructions”); cf. Ball v. State, 347 Md. 156, 190 , 699 A.2d 1170, 1186 (1997)(observing that Md.

11
Mills v. Stategreen
mdctspecapp · 1971 · cited in 1 Maryland opinions naming this issue, 1998–1998
2 sentences

1998The negligence variety of involuntary manslaughter requires a gross deviation from the standard of care an ordinary person would use, ie., the conduct must manifest “ ‘a wanton or reckless disregard of human life.’ ” Albrecht, 336 Md. at 499 , 649 A.2d at 348 (quoting Mills v. State, 13 Md.App. 196, 200 , 282 A.2d 147, 149 (1971), cert. denied, 264 Md. 750 (1972)). *292 Since the prosecution in this case had not entered a nolle prosequi of the charged offense of manslaughter, the trial court was required to give the manslaughter instruction so long as it was a permissible verdict generated by

1998The negligence variety of involuntary manslaughter requires a gross deviation from the standard of care an ordinary person would use, ie., the conduct must manifest “ ‘a wanton or reckless disregard of human life.’ ” Albrecht, 336 Md. at 499 , 649 A.2d at 348 (quoting Mills v. State, 13 Md.App. 196, 200 , 282 A.2d 147, 149 (1971), cert. denied, 264 Md. 750 (1972)). *292 Since the prosecution in this case had not entered a nolle prosequi of the charged offense of manslaughter, the trial court was required to give the manslaughter instruction so long as it was a permissible verdict generated by

11
Lansdowne v. Stategreen
md · 1980 · cited in 1 Maryland opinions naming this issue, 1998–1998
2 sentences

1998See Maryland Rule 4-325(e)(“The court may, and at the request of any party shall, instruct the jury as to the applicable law and the extent to which the instructions are binding.”); Lansdowne v. State, 287 Md. 232, 239 , 412 A.2d 88, 91 (1980)(holding that the trial judge must “give a requested instruction which correctly states the applicable law and which has not been fairly covered in instructions”); cf. Ball v. State, 347 Md. 156, 190 , 699 A.2d 1170, 1186 (1997)(observing that Md.

1998See Maryland Rule 4-325(e)(“The court may, and at the request of any party shall, instruct the jury as to the applicable law and the extent to which the instructions are binding.”); Lansdowne v. State, 287 Md. 232, 239 , 412 A.2d 88, 91 (1980)(holding that the trial judge must “give a requested instruction which correctly states the applicable law and which has not been fairly covered in instructions”); cf. Ball v. State, 347 Md. 156, 190 , 699 A.2d 1170, 1186 (1997)(observing that Md.

11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in Maryland. Read the followed side critically anyway.

Also cited on this issue (13)

CaseCitedYears
Williams v. State green
mdctspecapp · 1994
1 sentence

2021The circumstances in Williams, 101 Md.

12021–2021
State v. Merrill green
utahctapp · 2012
1 sentence

2020Merrill argued that there was no evidence of criminal culpability because “co-sleeping with an infant does not create a substantial and unjustifiable risk of injury or death to an infant nor does it constitute a gross deviation from the standard of care that an ordinary person would exercise.” Id. at 203 .

12020–2020
State v. Butler green
tenncrimapp · 1994
1 sentence

2014In Butler, 880 S.W.2d at 397 , the court stated that the statutory definition of criminal negligence related to “(1) the defendant’s conduct, (2) a substantial and justifiable risk existing at the time of the conduct or resulting from the conduct, (3) the defendant’s failure ... to perceive the risk, and (4) that failure being a gross deviation from the standard of care.” 7 *683 Under those circumstances, the court held that “the statutory definition provides adequate notice of what conduct is covered.” In State v. Randol, 226 Kan. 347 , 597 P.2d 672, 673 (1979), the Kansas Supreme Court addre

12014–2014
State v. Albrecht green
md · 1994
2 sentences

1998The negligence variety of involuntary manslaughter requires a gross deviation from the standard of care an ordinary person would use, ie., the conduct must manifest “ ‘a wanton or reckless disregard of human life.’ ” Albrecht, 336 Md. at 499 , 649 A.2d at 348 (quoting Mills v. State, 13 Md.App. 196, 200 , 282 A.2d 147, 149 (1971), cert. denied, 264 Md. 750 (1972)). *292 Since the prosecution in this case had not entered a nolle prosequi of the charged offense of manslaughter, the trial court was required to give the manslaughter instruction so long as it was a permissible verdict generated by

1998The negligence variety of involuntary manslaughter requires a gross deviation from the standard of care an ordinary person would use, ie., the conduct must manifest “ ‘a wanton or reckless disregard of human life.’ ” Albrecht, 336 Md. at 499 , 649 A.2d at 348 (quoting Mills v. State, 13 Md.App. 196, 200 , 282 A.2d 147, 149 (1971), cert. denied, 264 Md. 750 (1972)). *292 Since the prosecution in this case had not entered a nolle prosequi of the charged offense of manslaughter, the trial court was required to give the manslaughter instruction so long as it was a permissible verdict generated by

11998–1998
Commonwealth v. Knight green
pasuperct · 1992
1 sentence

1994Id. 611 A.2d at 1204 . (quoting 18 Pa.Cons.Stat.Ann. § 302(b)(3)).

11994–1994
Minor v. State green
md · 1992
2 sentences

1993In Minor v. State, 326 Md. at 443 , 605 A.2d 138 , Chief Judge Murphy set out the test for recklessness in this state: “The test is whether the appellant’s misconduct, viewed objectively, was so reckless as to constitute a gross departure from the standard of conduct that a law-abiding person would observe, and thereby create the substantial risk that the statute was designed to punish.” (emphasis supplied).

1993In Minor v. State, 326 Md. at 443 , 605 A.2d 138 , Chief Judge Murphy set out the test for recklessness in this state: “The test is whether the appellant’s misconduct, viewed objectively, was so reckless as to constitute a gross departure from the standard of conduct that a law-abiding person would observe, and thereby create the substantial risk that the statute was designed to punish.” (emphasis supplied).

11993–1993
People v. Carlton green
illappct · 1975
2 sentences

1991To the same effect see Goffer v. State, 430 So.2d 896 (Ala.Crim.App.1983); Slay v. State, 508 So.2d 1268 (Fla.App.1987); Navarro v. State, 433 So.2d 1011 (Fla.App.1983); People v. Schwartz, 64 Ill.App.3d 989 , 21 IIl.Dec. 765, 382 N.E.2d 59 (1978); People v. Carlton, 26 Ill.App.3d 995 , 326 N.E.2d 100 (1975); State v. Hardie, 47 Iowa 647 , 29 Am.

1991To the same effect see Goffer v. State, 430 So.2d 896 (Ala.Crim.App.1983); Slay v. State, 508 So.2d 1268 (Fla.App.1987); Navarro v. State, 433 So.2d 1011 (Fla.App.1983); People v. Schwartz, 64 Ill.App.3d 989 , 21 IIl.Dec. 765, 382 N.E.2d 59 (1978); People v. Carlton, 26 Ill.App.3d 995 , 326 N.E.2d 100 (1975); State v. Hardie, 47 Iowa 647 , 29 Am.

11991–1991
People v. Andersch green
illappct · 1982
2 sentences

1991The court said that “[i]t is settled that pointing a loaded weapon at another constitutes recklessness since it is a gross deviation from the standard of care exercised by a reasonable person,” and that “the trier of fact could have properly determined that the defendant acted recklessly in not checking the condition of the weapon prior to the incident.” Id. at 818 , 63 IIl.Dec. at 557, 438 N.E.2d at 488 .

1991The court said that “[i]t is settled that pointing a loaded weapon at another constitutes recklessness since it is a gross deviation from the standard of care exercised by a reasonable person,” and that “the trier of fact could have properly determined that the defendant acted recklessly in not checking the condition of the weapon prior to the incident.” Id. at 818 , 63 IIl.Dec. at 557, 438 N.E.2d at 488 .

11991–1991
Goffer v. State green
alacrimapp · 1983
1 sentence

1991To the same effect see Goffer v. State, 430 So.2d 896 (Ala.Crim.App.1983); Slay v. State, 508 So.2d 1268 (Fla.App.1987); Navarro v. State, 433 So.2d 1011 (Fla.App.1983); People v. Schwartz, 64 Ill.App.3d 989 , 21 IIl.Dec. 765, 382 N.E.2d 59 (1978); People v. Carlton, 26 Ill.App.3d 995 , 326 N.E.2d 100 (1975); State v. Hardie, 47 Iowa 647 , 29 Am.

11991–1991
State v. Bailey green
fladistctapp · 1987
1 sentence

1991To the same effect see Goffer v. State, 430 So.2d 896 (Ala.Crim.App.1983); Slay v. State, 508 So.2d 1268 (Fla.App.1987); Navarro v. State, 433 So.2d 1011 (Fla.App.1983); People v. Schwartz, 64 Ill.App.3d 989 , 21 IIl.Dec. 765, 382 N.E.2d 59 (1978); People v. Carlton, 26 Ill.App.3d 995 , 326 N.E.2d 100 (1975); State v. Hardie, 47 Iowa 647 , 29 Am.

11991–1991
People v. Schwartz green
illappct · 1978
2 sentences

1991To the same effect see Goffer v. State, 430 So.2d 896 (Ala.Crim.App.1983); Slay v. State, 508 So.2d 1268 (Fla.App.1987); Navarro v. State, 433 So.2d 1011 (Fla.App.1983); People v. Schwartz, 64 Ill.App.3d 989 , 21 IIl.Dec. 765, 382 N.E.2d 59 (1978); People v. Carlton, 26 Ill.App.3d 995 , 326 N.E.2d 100 (1975); State v. Hardie, 47 Iowa 647 , 29 Am.

1991To the same effect see Goffer v. State, 430 So.2d 896 (Ala.Crim.App.1983); Slay v. State, 508 So.2d 1268 (Fla.App.1987); Navarro v. State, 433 So.2d 1011 (Fla.App.1983); People v. Schwartz, 64 Ill.App.3d 989 , 21 IIl.Dec. 765, 382 N.E.2d 59 (1978); People v. Carlton, 26 Ill.App.3d 995 , 326 N.E.2d 100 (1975); State v. Hardie, 47 Iowa 647 , 29 Am.

11991–1991
Navarro v. State green
fladistctapp · 1983
1 sentence

1991To the same effect see Goffer v. State, 430 So.2d 896 (Ala.Crim.App.1983); Slay v. State, 508 So.2d 1268 (Fla.App.1987); Navarro v. State, 433 So.2d 1011 (Fla.App.1983); People v. Schwartz, 64 Ill.App.3d 989 , 21 IIl.Dec. 765, 382 N.E.2d 59 (1978); People v. Carlton, 26 Ill.App.3d 995 , 326 N.E.2d 100 (1975); State v. Hardie, 47 Iowa 647 , 29 Am.

11991–1991
State v. Hardie green
iowa · 1878
1 sentence

1991To the same effect see Goffer v. State, 430 So.2d 896 (Ala.Crim.App.1983); Slay v. State, 508 So.2d 1268 (Fla.App.1987); Navarro v. State, 433 So.2d 1011 (Fla.App.1983); People v. Schwartz, 64 Ill.App.3d 989 , 21 IIl.Dec. 765, 382 N.E.2d 59 (1978); People v. Carlton, 26 Ill.App.3d 995 , 326 N.E.2d 100 (1975); State v. Hardie, 47 Iowa 647 , 29 Am.

11991–1991

Where else courts name it

TX 190 (1976–2026) NY 140 (1972–2025) IL 134 (1964–2026) CA 108 (1983–2026) PA 107 (1977–2026) TN 66 (1994–2026) OR 66 (1975–2026) MO 52 (1987–2025) GA 43 (1988–2026) CT 39 (1981–2025) KY 25 (1987–2026) UT 25 (1983–2026) ME 22 (1979–2025) AL 20 (1985–2025) NJ 19 (1979–2025) DE 16 (2003–2025) CO 15 (1982–2026) AZ 14 (1988–2024) WA 13 (1979–2024) KS 13 (2008–2026) NM 13 (2009–2023) HI 12 (1995–2026) AR 10 (1985–2026) VT 10 (1992–2025) MD 8 (1991–2022) AK 8 (1982–2023) MN 6 (1991–2015) WY 5 (1993–2024) NH 5 (2005–2017) LA 4 (1971–1991) FL 4 (1979–2017) MT 3 (1985–2006) MA 3 (2016–2025) WI 3 (2013–2013) DC 3 (2015–2017) MI 2 (2003–2017) NE 2 (1989–2002) OH 2 (1995–2000)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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