## Facts

- Warner-Lambert manufactured “Freshen-Up” chewing gum at its Long Island City plant using magnesium stearate (MS), a dustlike lubricant, and a die-cut punch machine cooled with liquid nitrogen.
- The manufacturing process dispersed MS dust into the air and allowed dust to accumulate around machinery and on overhead surfaces.
- MS and liquid nitrogen were widely used and generally considered safe, but suspended MS dust at sufficient concentration posed an explosion risk if ignited.
- On November 21, 1976, employees were cleaning settled MS dust near the remaining operating machine by broom sweeping and blowing with compressed air.
- A catastrophic explosion occurred near the operating machine, followed shortly by a larger explosion and fire.
- Six employees died and more than fifty were injured.
- Expert proof suggested competing ignition theories (e.g., a mechanical/electrical spark or a chain involving liquid oxygen formation), but the initiating event was not determined.
- The People alleged defendants knew of an explosion hazard tied to MS dust and failed to implement recommended safety measures fully, making continued operations reckless or criminally negligent.

## Issues

1. Whether Grand Jury evidence was legally sufficient to support second-degree manslaughter or criminally negligent homicide charges when defendants allegedly knew of a general explosion risk from MS dust but the explosion’s triggering cause was unknown and not reasonably foreseeable.
2. Whether criminal causation and the mens rea for recklessness or criminal negligence require proof that the particular fatal occurrence (or causal chain producing it) was a foreseeable result of defendants’ conduct.

## Decision

- The Court of Appeals reversed the Appellate Division and reinstated the trial court’s dismissal of the indictment for legal insufficiency.
- The court held the evidence did not establish a sufficiently direct and foreseeable causal connection between defendants’ conduct and the deaths.
- Awareness of a broad, undifferentiated risk of explosion from ambient MS dust did not support criminal liability where the triggering cause of the explosion was neither foreseen nor foreseeable.
- Because the initiating mechanism remained speculative, the Grand Jury proof did not establish the causation element required for either manslaughter or criminally negligent homicide.

## Legal Principles

- On a motion to dismiss an indictment for legal insufficiency, courts ask whether competent evidence, viewed most favorably to the prosecution, would establish every element of the charged offense and the defendant’s commission of it.
- Criminal homicide liability requires a sufficiently direct causal connection between the defendant’s conduct and the death; generalized dangerousness is not enough.
- For recklessness and criminal negligence, the relevant risk must correspond to the kind of result that occurred; foreseeability limits both culpability and proximate cause in criminal cases.
- Criminal responsibility demands a narrower, more direct causal showing than civil tort liability; criminal law does not treat defendants as guarantors against all harms flowing from hazardous conditions once a general risk is known.

## Conclusion

The court dismissed the homicide indictment because, although the defendants could be charged with awareness of a general dust-explosion hazard, the Grand Jury evidence did not show that the specific triggering cause and fatal chain of events were reasonably foreseeable, defeating criminal causation and the required culpable mental states.


People v. Warner-Lambert Co., 51 N.Y.2d 295, 414 N.E.2d 660 (N.Y. 1980)