R v Price [2014] EWCA Crim 2213 (Court of Appeal)

Court: Court of Appeal

Facts: The defendant (D), a nurse, was tasked with caring for a patient with complex needs. Despite the patient’s deteriorating condition, D failed to perform basic medical interventions, including monitoring vital signs and escalating the situation to senior staff. The patient eventually died due to these failures. The prosecution argued that D's grossly negligent care resulted in the patient's death.

Held: The Court of Appeal held that in assessing gross negligence manslaughter, the reasonableness of D's conduct should be judged in light of her position as a nurse, her level of training, knowledge, and experience (or lack thereof). The court emphasized that the standard of care for gross negligence must take into account the professional role and qualifications of the individual involved.

💡Levelup: The case reinforced the principles of gross negligence, highlighting that the standard of care can vary depending on the defendant's professional role and expertise. It underscored that a professional's failings in a context where the duty of care is paramount could amount to criminal conduct if it meets the gross negligence threshold.