from
Bouvier's Law Dictionary, Revised 6th Ed (1856)
GROSS NEGLIGENCE. Lata culpa, or, as the Roman lawyers most accurately call
it) dolo proxima, is, in practice, considered as equivalent to dolus or
fraud itself, and consists, according to the best interpreters, in the
omission of that care which even inattentive and thoughtless men never fail
to take of their own property. Jones on Bailments, 20. It must not be
confounded, however, with fraud, for it may exist consistently with good
faith and honesty of intention, according to common law authorities.