People v. Beardsley

Beardsley was a married man whose wife was away visiting relatives. He spent a weekend drinking with Blanche Burns, a woman he was having an affair with. During the weekend, Burns took several tablets of morphine. When she became unconscious, Beardsley did not call a doctor or seek medical aid but instead had a friend take Burns to another room in the basement, where she subsequently died from the morphine overdose. Beardsley was charged with manslaughter for failing to summon medical assistance.

The court reasoned that criminal liability for omissions requires a legal duty to act, not merely a moral obligation. The law recognizes specific categories of relationships that impose affirmative duties, including parent-child, spouse, employer-employee, and contractual relationships. The relationship between Beardsley and Burns, while perhaps morally significant, did not fall within any of these recognized categories. The court emphasized that the common law draws a clear line between legal and moral duties and that expanding criminal liability for omissions beyond established categories would create unmanageable standards. The court acknowledged that Beardsley's failure to act was morally reprehensible but held that moral culpability alone is insufficient for criminal liability.

People v. Beardsley remains the most frequently cited case for the proposition that criminal liability for omissions requires a specific legal duty to act. It is a standard teaching case for the act/omission distinction and the categories of legal duty. The case has been criticized for its narrow view of duty, particularly in contexts involving cohabitants and voluntary assumption of care. Some jurisdictions have subsequently expanded the categories of duty, and the MPC recognizes a duty based on voluntary assumption of care.