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State v. Hazelwood

    Citation. 946 P.2d 875,1997 Alas. 138 Oil & Gas Rep. 245

    Brief Fact Summary. Appellant was the captain of the Exxon Valdez when it leaked millions of gallons of oil into the water. Appellant alleges that the State must prove criminal negligence and that a standard of civil negligence is in violation of his Due Process rights under the Constitution of the United States.

    Synopsis of Rule of Law. A simple civil negligence showing is both necessary and sufficient and constitutionally permitted because it aims at assuring that criminal penalties will be imposed only when the conduct at issue is something society can reasonably expect to deter.


    Facts. Appellant was the captain of the Exxon Valdez that ran aground and leaked 11 million gallons of oil into Alaska’s Prince William Sound. A jury convicted Appellant of negligent discharge of oil. The Appellate Court reversed on the basis that Appellant should have been charged under a criminal negligence theory rather than a civil negligence standard of culpability.

    Issue. Whether the standard of civil negligence for the charge Appellant was convicted is a sufficient standard under Due Process Clause of Alaska’s Constitution.

    Held. The Trial Court’s adoption of ordinary civil negligence standard is adequate to protect Appellant’s interests.
    A mental state of simple or ordinary negligence can support a criminal conviction. However, in some situations, more will be required and sometimes less.

    For some offenses, a simple civil negligence showing is both necessary and sufficient and constitutionally permitted because it aims at assuring that criminal penalties will be imposed only when the conduct at issue is something society can reasonably expect to deter.

    Dissent. The dissent argued that fairness required a showing of something more than civil negligence. A punishment of imprisonment is sufficiently severe that something more than civil negligence should be required in order to impose the punishment.

    Discussion. The Court ruled that it is a firmly established principle that ordinary civil negligence will be sufficient for some criminal convictions. Furthermore, the Court noted that there were some offenses where strict liability was imposed. The plain reading of the statute, the Court ruled, supported a finding that the statute only required civil negligence and not the higher standard of criminal negligence.


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