Connecticut v. White

Facts

D owned a three-family residential building in New Britain. On December 25, 1982, a fire broke out. The occupant of the first-floor apartment awoke to find smoke filtering into his apartment. After waking up his wife, their child, and his brother-in-law, and escorting them outside, the occupant summoned the New Britain fire department. The fire department arrived at the scene almost immediately and began battling a fire that had broken out on the second floor. Firefighters entered the second-floor apartment and discovered the bodies of Maryann Jones and her two young children, Lindsay and Brandy, the occupants of that apartment, lying dead on the floor. The medical examiner concluded that all three had died from asphyxia caused by smoke inhalation. The fire was caused by an electrical overload from a wall outlet into which a quartz heater had been plugged, began smoldering at approximately 2:30 a.m., but did not break out in the apartment until about 5:30 a.m. As a result of the slow-burning nature of the fire, the apartment was covered with soot and was filled with thick smoke. There were no smoke detectors in the building. Testimony was introduced that had smoke detectors been installed in the building, the occupants would have been alerted to the fire in sufficient time to enable them to escape. D owned another multifamily apartment building located in East Hartford. In May 1982, D received notice from the East Hartford fire marshal informing him that he was required to furnish smoke detectors in his East Hartford building. The defendant installed smoke detectors in the East Hartford building, but he did not install smoke detectors in his New Britain building. Prior to December 1982, D undertook renovations on the New Britain property but did not obtain building permits for the work he performed. D moved for a judgment of acquittal which was denied. D was found guilty and D appealed.

Issues

Rule of Law

Holding and Decision

Legal Analysis

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