People v. Reyes

In People v. Reyes (75 NY2d 590, 554 N.E.2d 67, 555 N.Y.S.2d 30 [1990]), a case most similar on its facts to this case, it was the landlord defendant himself who created an illegal SRO and then entered into a lease for another person to manage the building while defendant retained ownership. The building was rife with electrical violations issued to defendant, and a fire caused by these electrical deficiencies killed a tenant. The Court of Appeals upheld the landlord's indictment for Criminally Negligent Homicide based on the numerous electrical hazards and structural deficiencies that facilitated the spread of the fire, and held that it was reasonably foreseeable that the conditions created a substantial and unjustifiable risk of death or injury in a fire. (Reyes, 75 NY2d at 593).