## Facts

- Howard Franklin Sealy drove on Wiregrass Road, which had a stop sign at its intersection with Bethesda Church Road, a through highway.
- Sealy’s vehicle entered the intersection and collided with a vehicle traveling on Bethesda Church Road.
- The collision killed two occupants of the other vehicle, Ralph Bullock and Guthrie Johnson Rhodes.
- Sealy was indicted on two counts of involuntary manslaughter.
- Sealy contended he stopped at the stop sign and did not see the other vehicle’s lights before entering the intersection.
- After the close of evidence, the trial court read to the jury G.S. § 20-158 (stop-sign/through-highway statute) and G.S. § 20-140 (reckless driving statute).
- The court then gave two separate instructions describing when statutory violations could constitute culpable negligence supporting involuntary manslaughter.

## Issues

1. Whether the trial court committed prejudicial error by giving conflicting jury instructions on culpable negligence that permitted conviction for involuntary manslaughter based on a stop-sign violation plus proximate cause, without requiring intentional, willful, wanton, or reckless misconduct.

## Decision

- The Supreme Court of North Carolina reversed the judgments and ordered a new trial.
- The court held the jury instructions were conflicting on the element of culpable negligence.
- The court concluded the conflict was prejudicial because the jury could have convicted under an erroneous standard that required only a statutory violation and proximate cause.

## Legal Principles

- Criminal culpable negligence requires more than civil actionable negligence.
- An intentional, willful, or wanton violation of a safety statute that proximately results in death constitutes culpable negligence supporting involuntary manslaughter.
- An unintentional or inadvertent violation of a safety statute, standing alone, does not constitute culpable negligence; it must be accompanied by conduct showing reckless disregard of probable dangerous consequences amounting to thoughtless disregard or heedless indifference to the safety of others.
- Under G.S. § 20-158, failure to stop at a stop sign is not negligence per se in civil actions and may be considered only with other circumstances; a jury instruction in a criminal case may not treat the bare failure to stop, plus proximate cause, as sufficient for manslaughter.
- Conflicting instructions on the required culpable-negligence standard require a new trial when the jury may have relied on the incorrect instruction.

## Conclusion

Because the jury was told both (1) that guilt required an intentional violation of a safety statute causing death and (2) that guilt could be found from a stop-sign violation causing death without an intentional or reckless mental state, the instructions misstated and conflicted on culpable negligence; the resulting convictions for involuntary manslaughter were reversed and the case remanded for a new trial.


State v. Sealy, 253 N.C. 802, 117 S.E.2d 793 (N.C. 1961)