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People v. Hall

999 P.2d 207 (Colo. 2000)

tl;dr: A ski instructor who decided to ski too quickly without control and technique acted with sufficient recklessness to sustain a conviction for reckless manslaughter.

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Nathan Hall was charged with reckless manslaughter after colliding with Allen Cobb while skiing on Vail mountain, resulting in Cobb's death. The county court dismissed the charges, but the district court found that Hall's conduct constituted a substantial and unjustifiable risk of death, and he must stand trial for reckless manslaughter. The prosecution provided sufficient evidence to show probable cause that the defendant recklessly caused the victim's death, and the case is remanded to the district court for trial. The court held that whether the defendant committed reckless manslaughter must be determined by the trier of fact based on the particular circumstances of the case. The prosecution requested that the court consider the lesser charge of criminally negligent homicide, which the lower court did not consider. During the preliminary hearing, eyewitnesses, a coroner, an investigator, and a detective testified that Hall was skiing recklessly and out of control, passing Judge Allen at a high rate of speed with his arms out to maintain balance and skiing straight down the slope without turning. Hall collided with Cobb, an inexperienced skier who was traversing the slope below him, and struck Lemaner's skis and poles after the collision. To be charged with reckless manslaughter, a person must have consciously disregarded a substantial and unjustifiable risk that their actions could cause the death of another person.

The prosecution appealed the dismissal of the manslaughter charge against Hall to the district court, which agreed with the county court that there was no probable cause. The court is considering two issues in this appeal: (1) whether the district court erred in establishing "more likely than not" as the level of substantial risk of death for a finding of probable cause in a manslaughter charge, and (2) whether the district court reviewed the wrong criteria and neglected evidence in affirming the county court's dismissal of the charge. The court reviews the history of culpable mental states and the elements of recklessness, which require an actor to consciously disregard a substantial and unjustifiable risk. To determine whether a risk is substantial and unjustified, a trier of fact must weigh the likelihood and potential magnitude of harm and consider whether the conduct constitutes a gross deviation from the reasonable standard of care.

The Model Penal Code recommends clear definitions of mental states for criminal liability. In Colorado, recklessness must be proven in manslaughter cases. The district court erred in requiring a higher level of risk for recklessness. Recklessness requires a gross deviation from the reasonable standard of care. The court can infer awareness of risk based on knowledge or expertise. The standard for reviewing probable cause is abuse of discretion. The prosecution presented sufficient evidence that Hall's skiing created a substantial and unjustifiable risk of death. The court must determine if Hall's conduct constituted a "gross deviation" from the standard of care.

Skiers have a duty to avoid collisions and Hall's conduct was a gross deviation from the standard of care, making him liable for civil negligence. Hall may be charged with reckless manslaughter based on evidence presented at the preliminary hearing. The evidence establishes probable cause but not necessarily proof beyond a reasonable doubt. The case is sent back to the district court for trial.

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Facts & Holding

Facts:Hall was an experienced ski instructor. He was skiing very...

Holding:Hall acted recklessly because he engaged in conduct that created...

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People v. Hall

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