People v. Young – New York
Nature of the Case
This case involves the law of self defense and intervention by a third party. The issue is whether a third party is criminally liable if he reasonably intervenes in a situation where a lawful arrest is proceeding.
Facts
On October 17, 1958 in Manhattan, Young saw two men assaulting a younger man as the younger man called for help. Young, who was not acquainted to any party, did not know that the two men were plains clothes police officers who were arresting the other younger man. Young intervened and tried to help the younger man whom he reasonably thought was being assaulted by the two older men. During the altercation Young became tied up with one of the police officers and the officer fell down, breaking his kneecap. Young was tried and convicted of third degree assault and appealed.
Issue
- If a third party intervenes reasonably, but mistakenly, in a lawful arrest, may he be held criminally liable?
Holding and Rule of Law
- No. If a third party intervenes reasonably, but mistakenly, in a lawful arrest he may not be held criminally liable.
Assault and battery is an ancient crime that requires intent. The mistake of fact in this type of crime relates to the men rea element. The modern view is not to impose criminal liability in connection with intent crimes upon those who act in good faith and with good motivation. This has been supported by the American Law Institute and the model penal code. In this case if Young had been correct in his reasonable beliefs he would have been a hero.
Disposition
Reversed.
Dissent (Valentine)
I would affirm the conviction because the intent to commit the battery was proven without doubt. Specific intent crimes allow for defenses based upon good faith mistakes as in this case. Assault however is a general intent crime and a reasonable mistake of fact will not work as a defense. In addition, the rescuer’s rights should be no greater than the person that he tries to rescue. Young should be allowed to fill the shoes of the perceived victim, but to allow him greater rights would set a dangerous precedent and would put plains clothes police officers in harm’s way.
Notes
The majority American rule is stated in the dissent: a third party may step in the shoes of the perceived victim, but a mistake of fact, even if it is reasonable, will not shield him from criminal liability.