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United States v. Youts | 229 F.3d 1312 (2000)
Imagine a night of mischief takes a turn for the worse. Can—and should—a person be criminally liable for knowingly causing damage, even if that person didn’t specifically intend to cause the damage? The Tenth Circuit Court of Appeals case of United States versus Youts cautions that if you set a locomotive in motion, be prepared to pay for what’s around the bend.
In January nineteen ninety-four, Abner Youts and Richard Nesbitt spent the night out on the town in Wichita, Kansas. In the early morning hours, Youts and Nesbitt decided to make their way home but did not have transportation. Although they had stolen a truck earlier in the evening, the truck was useless after the pair drove it into a pond.
While walking home along the tracks, Youts and Nesbitt discovered two connected, idling trains. They jumped on board and figured out how to maneuver them. Youts then drove the connected trains to about half a block from his house, dropped off Nesbitt, and decided to disembark. But before he did, Youts sent the train back into Wichita by putting the engine in reverse at full speed. The trains derailed in downtown Wichita when they hit a curve at about fifty-six miles per hour, whereas the recommended speed for the curve was ten miles per hour. One of the train cars landed on its side next to the tracks and the other stopped in the street. Fortunately, no one was hurt, but the wreckage cost the City of Wichita and the train company over two hundred and thirty-four thousand dollars in damages.
Youts and Nesbitt were charged with violating a federal law making it a crime to willfully derail, disable, or wreck a train. Nesbitt testified against Youts in a Kansas federal district court, and the jury found Youts guilty. Youts was sentenced to forty-six months in prison and ordered to pay the damages.
Youts appealed to the Tenth Circuit Court of Appeals. He argued the evidence was insufficient to find that he willfully wrecked the train. Instead, he argued, the evidence only established that he impulsively took the train but intended to return the train to the station when he was finished.
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