People v. Goetz, 73 N.Y.2d 97 (1988)
A defendant is entitled to a jury instruction on the justification defense if, based on a reasonable view of the evidence, the jury could conclude the defendant’s actions were justified, even in the context of criminally negligent homicide.
Summary
After consuming alcohol, the defendant was involved in a minor traffic accident. Fearing the other driver, he fled the scene, striking and killing a pedestrian, Frank Flotteron. He was convicted of criminally negligent homicide. The Court of Appeals held that the evidence was sufficient to support the conviction, but the trial court erred in refusing to instruct the jury on the justification defense regarding the homicide counts. Because the court instructed the jury on justification for leaving the scene, the defendant was entitled to have the jury consider if the *manner* in which he fled the scene (speeding) was also justified. The order was modified to vacate the conviction for criminally negligent homicide and order a new trial.
Facts
At 4:20 a.m. on a Saturday, the defendant was involved in a minor traffic accident in New York City.
According to the defendant, the other driver became belligerent and reached into his backseat, leading the defendant to believe he was about to produce a weapon.
The defendant returned to his car and fled the scene.
A short distance away, the defendant struck and killed Frank Flotteron, a pedestrian.
Witnesses estimated the defendant’s speed at 50-100 mph in a 35-mph zone, and the defendant admitted to running several red lights.
Procedural History
The defendant was indicted for second-degree manslaughter, second-degree vehicular manslaughter, driving while intoxicated, and two counts of leaving the scene of an accident.
The trial court dismissed the felony count of leaving the scene of the *fatal* accident.
The jury convicted the defendant of two counts of criminally negligent homicide (lesser included offenses of manslaughter and vehicular manslaughter) and driving while impaired (lesser included offense of driving while intoxicated).
The jury found the defendant not guilty