## Facts

- Mario Jaime Escamilla worked for the General Motors Defense Research Laboratory at a research station on Fletcher’s Ice Island T-3, a drifting mass of glacial ice in the Arctic Ocean used as a long-term U.S.-supported research platform.
- Bennie Lightsey, a U.S. Weather Bureau employee, served as station manager; both men were part of a small group stationed on T-3 for several months in 1970.
- T-3 had no medical facilities, no medically trained personnel, and removal of a wrongdoer was practically impossible due to isolation.
- After tensions developed among the crew, Escamilla shot Lightsey with a rifle; Lightsey died from the wound.
- There were no eyewitnesses to the shooting, and the government’s case relied on circumstantial evidence.
- Evidence at trial supported a defense theory that the rifle could discharge without pulling the trigger and that this defect was not reasonably foreseeable to Escamilla.
- Escamilla was prosecuted in federal court for involuntary manslaughter under 18 U.S.C. § 1112 on the theory that the killing occurred within the special maritime and territorial jurisdiction of the United States.

## Issues

1. Whether a drifting Arctic ice island research station (T-3) fell within the “special maritime and territorial jurisdiction of the United States,” permitting prosecution under federal criminal law.
2. Whether errors in the admission or presentation of evidence and/or jury instructions denied Escamilla a fair trial in a circumstantial involuntary manslaughter case involving an accident/defective-weapon theory.

## Decision

- The en banc court affirmed the district court’s exercise of federal jurisdiction because the court was equally divided on the jurisdiction question.
- The court reversed Escamilla’s conviction due to trial errors and remanded for a new trial.
- The court did not direct an acquittal, indicating the evidence was not legally insufficient as a matter of law, but the proceedings were defective enough to require retrial.

## Legal Principles

- An affirmance by an equally divided en banc court leaves the lower court’s ruling in place for the case but does not resolve the disputed legal question by precedential holding.
- In a circumstantial homicide prosecution where a defendant presents evidence of an unforeseeable mechanical defect supporting an accident theory, trial courts must ensure evidentiary rulings and jury instructions allow the jury to assess accident versus criminal negligence under the governing manslaughter standard.
- Reversal and remand for retrial is appropriate when prejudicial trial errors undermine the fairness of the proceedings, even if the record could support submission of the case to a properly instructed jury.

## Conclusion

The Fourth Circuit, sitting en banc, left intact the district court’s assertion of federal jurisdiction over a killing on T-3 because the court split evenly on that issue, but it reversed Escamilla’s involuntary manslaughter conviction for prejudicial trial errors and remanded for a new trial.


United States v. Escamilla, 467 F.2d 341 (4th Cir. 1972) (en banc)