KORONER’S KORNER: Missouri Manner of Death Classifications

The Coroner of Butler County, Jim Akers, has graciously allowed me to use his essays as I try to educate the public on coroner authorities and duties.  RSMO 58.451 demands coroners investigate the manner of death and the manner on each death certificate.  This paper should aid in understanding the differences in manners of death.

Following is a comprehensive legal analysis of the classification of manner of death under Missouri law, Black’s Law Dictionary, case law, and common law doctrine.  It specifically supports the position that a death may only be classified as ‘accidental’ when the decedent’s own actions caused their death.  When the death is caused by another human being—regardless of intent—it is properly classified as a ‘homicide’ under the legal definition of that term.  This document also includes a breakdown of traditional manner-of-death classifications, legal definitions of homicide, the Missouri statute on accidental acts, and a clarified interpretive standard for coroners.

I. Recognized Manners of Death in Missouri

Natural   Legal Definition: Death caused solely by disease or the aging process, with no external factors involved.   Example: A person dies at home of a heart attack due to coronary artery disease.

Accidental Legal Definition: Death caused by an unintentional external factor, typically classified as such when no human agency caused the death.  Example: A person dies from a fall they caused themselves.

Suicide Legal Definition: Death caused by the intentional taking of one’s own life.  Example: A person intentionally overdoses on prescription drugs.

Homicide Legal Definition: The killing of one human being by the act, procurement, or omission of another.  Example: A person is shot and killed by another, whether criminally (e.g., during a robbery) or lawfully (e.g., self-defense).

Undetermined Legal Definition: Used when the evidence is insufficient to conclusively determine the manner of death.  This may be when two manners are equally possible (suicide/ accident) or (natural/Homicide)  Example: A decomposed body is discovered without a clear cause of death.

II. Legal Definition of Homicide

According to Black’s Law Dictionary (11th ed.), homicide is defined as: ‘The killing of one human being by the act, procurement, or omission of another.’ This definition is neutral and includes both lawful killings (e.g., self-defense) and unlawful killings (e.g., murder or manslaughter).  Missouri law and common law tradition align with this definition.

III. Subcategories of Homicide

A. Lawful Homicide

1. Justifiable Homicide   Definition: A killing that is legally permitted, such as in defense of oneself or others.  Example: A homeowner fatally shoots an armed intruder threatening their family.

2. Excusable Homicide   Definition: A killing resulting from accident or misfortune during lawful conduct and without unlawful intent or gross negligence.  Example: A hunter accidentally kills another hunter without negligence while legally hunting.

B. Criminal Homicide

1. First-Degree Murder (RSMo § 565.020)   Definition: Deliberate, premeditated killing or killing during certain felonies.  Example: Example: A person kills during a planned robbery.

2. Second-Degree Murder (RSMo § 565.021)   Definition: Intentional killing without premeditation, or death during a felony.  Example: A person kills another during a spontaneous fight.

3. Voluntary Manslaughter (RSMo § 565.023)   Definition: Killing in the heat of passion due to adequate provocation.  Example: A spouse kills immediately upon discovering infidelity.

4. Involuntary Manslaughter (RSMo § 565.024, § 565.026)   Definition: Unintentional killing caused by recklessness or criminal negligence.  Example: A driver kills a pedestrian while texting.

IV. Missouri Law on Accidental Acts (RSMo § 563.070)

Missouri law provides that certain actions resulting in harm or death may be excused when they occur as accidents in the performance of lawful conduct.  According to RSMo § 563.070: ‘The use of physical force upon another person that would otherwise constitute an offense under chapter 565 is justifiable and not criminal when the actor does not intend to cause death or serious physical injury and such force is used by accident in the performance of a lawful act by lawful means, without criminal negligence or unlawful intent.’

Thus, unintentional deaths may be legally excused if all of the following are true: (1) the act was lawful, (2) the death was unintentional, (3) there was no criminal negligence, and (4) the actor did not intend harm.  However, even if a death is excused from criminal liability, it may still properly be classified as a homicide if caused by another person’s actions.

V. Coroner’s Interpretive Position on Manner of Death

The position held is that an unintentional death may only be classified as ‘Accidental’ when the decedent is solely responsible for their own death.  If another human being caused the death—whether through intent, recklessness, or negligence—the manner of death should be classified as ‘Homicide’.

VI. Clarification of Accidental Manner of Death

Coroner’s Interpretive Standard

To further clarify the application of ‘Accidental’ as a manner of death, the following interpretive standard is established for use within the jurisdictional practice of death investigation:

A death shall only be classified as ‘Accidental’ when it results from one of the following circumstances:

1. Natural or environmental forces beyond human control (e.g., tornado, lightning strike, earthquake).

2. Mechanical or structural failure without human causation or negligence (e.g., spontaneous mechanical malfunction).

3. Self-caused actions, injuries, or events in which no other person’s conduct, omission, or negligence was involved.

In contrast, any death resulting from the action, inaction, or influence of another person—regardless of intent—shall be classified as ‘Homicide’ based on the legal definition as the killing of one human being by another.

VII. Sources and Legal Authority

– Black’s Law Dictionary, 11th Edition, definition of ‘Homicide’.

– Missouri Revised Statutes § 565.020 – First-Degree Murder.

– Missouri Revised Statutes § 565.021 – Second-Degree Murder.

– Missouri Revised Statutes § 565.023 – Voluntary Manslaughter.

– Missouri Revised Statutes § 565.024, § 565.026 – Involuntary Manslaughter.

– Missouri Revised Statutes § 563.070 – Justification for accidental acts.

– State v. Beeler, 12 S.W.3d 294 (Mo. 2000) – Interpreting homicide in a broad sense.

– National Association of Medical Examiners (NAME) Guidelines on manner of death.

Danny Leo Green,

Coroner Cedar County