## Facts

- Carroll Beardsley, a married man in Pontiac, Michigan, spent a weekend drinking in his apartment with Blanche Burns, with whom he had a prior intimate relationship.
- From Saturday evening to Monday afternoon, they drank heavily; additional liquor was delivered to the apartment.
- On Monday, anticipating his wife’s return, Beardsley insisted the apartment be put in order and that Burns not be discovered there.
- Burns obtained camphor and morphine tablets; she concealed the morphine, but Beardsley and another person saw her put something in her mouth.
- Beardsley knocked a box from Burns’s hand and crushed some tablets, but Burns likely ingested several grains of morphine.
- Burns became stuporous. Beardsley, intoxicated and focused on avoiding his wife finding Burns, had Burns carried to a basement room occupied by a tenant and asked that she be watched and released when she awoke.
- Burns was later found dead; the prosecution attributed her death to morphine and alleged Beardsley committed manslaughter by failing to summon medical assistance or otherwise properly care for her.

## Issues

1. Whether Beardsley’s failure to obtain medical aid or take adequate steps to save Burns, after she ingested morphine, could constitute manslaughter based on omission.
2. Whether Beardsley and Burns’s relationship and circumstances created a legally recognized duty of care sufficient to support homicide liability for nonfeasance.

## Decision

- The Michigan Supreme Court reversed the manslaughter conviction and ordered Beardsley discharged.
- The court held that omission-based manslaughter requires breach of a legal duty imposed by law, not merely a moral obligation.
- The court found no statute, contract, or legally recognized special relationship that required Beardsley to rescue Burns or summon medical care.
- Burns was an adult companion/guest rather than a person in a custodial or dependent relationship that would impose a legal duty on Beardsley.

## Legal Principles

- Criminal liability for an omission in homicide requires a legally recognized duty to act; moral blameworthiness alone does not create criminal responsibility.
- A legal duty sufficient for omission liability typically arises from: (1) statute, (2) contract, (3) certain status relationships (e.g., parent-child, spouses), or (4) voluntary assumption of care that isolates the person from help by others.
- An illicit or informal companionship, without more, does not create the type of legal duty that supports manslaughter for failure to obtain aid.

## Conclusion

Because Beardsley lacked a legally imposed duty to rescue or obtain medical care for an adult companion under the circumstances, his failure to act could not support manslaughter liability, and the conviction was reversed with an order of discharge.


People v. Beardsley, 150 Mich. 206, 113 N.W. 1128 (Mich. 1907)