State v. MacMaster

752 P.2d 954, 51 Wash. App. 231
CourtCourt of Appeals of Washington
DecidedApril 28, 1988
Docket7828-1-III
StatusPublished
Cited by6 cases

This text of 752 P.2d 954 (State v. MacMaster) is published on Counsel Stack Legal Research, covering Court of Appeals of Washington primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. MacMaster, 752 P.2d 954, 51 Wash. App. 231 (Wash. Ct. App. 1988).

Opinions

Munson, J.

Michael S. MacMaster was convicted by a jury of vehicular homicide, RCW 46.61.520(1). We affirm. The only precedential issue is whether a specific jury instruction requiring the State to prove a causal connection between the intoxicated driver and the resulting death need be given. We hold the instructions given were sufficient to convey this element and provide a basis for closing arguments.

Michael MacMaster, driving a Porsche, struck and killed Rhonda Raber, who was standing behind her disabled car taking things out of the trunk. The Raber car was parked on the shoulder of the road, to the right of the lane Mr. MacMaster was traveling in, and protruded over the fog line into the lane of travel about 12 inches. Mr. Raber was in front of his car working on the engine. Another vehicle, belonging to Mrs. Daggy, was parked in front of the Raber car, facing the Raber car, with headlights on pointing into the oncoming lane of traffic where Mr. MacMaster was traveling.

There was conflicting testimony on the speed Mr. Mac-Master was traveling; estimates ranged from 50 to 80 m.p.h. A blood test of Mr. MacMaster revealed a blood alcohol level of .13. The accident occurred around 8 p.m.; it was dark and just starting to rain.

Mr. MacMaster testified he thought the blinding light from the Daggy car was a car with one headlight coming toward him in his lane, attempting to pass a car in its lane, and he slowed down and pulled to the right to avoid it. He found out later the Daggy car was parked facing oncoming traffic and not moving. He testified he neither saw the Raber car nor Mrs. Raber before hitting them.

[233]*233Several of the assignments of error made by Mr. MacMaster relate to errors in jury instructions. The test for sufficiency of jury instructions is whether the instructions, read as a whole, correctly state the applicable law, are not misleading, and allow counsel to argue their theory of the case.

The first issue is whether RCW 46.61.520 requires the State to prove a causal connection between intoxicated driving and the resulting death. We hold it does.

RCW 46.61.520 defines vehicular homicide as follows:

(1) When the death of any person ensues within three years as a proximate result of injury proximately caused by the driving of any vehicle by any person while under the influence of intoxicating liquor or any drug, as defined by RCW 46.61.502,. . .

Cases interpreting the negligent homicide statute, pre-1983 amendments, hold the statute requires the State to prove, as an essential element of the crime, a causal connection between the defendant's conduct (impairment of driving) and the resulting death. State v. Engstrom, 79 Wn.2d 469, 487 P.2d 205 (1971); State v. Mearns, 7 Wn. App. 818, 502 P.2d 1228 (1972), review denied, 81 Wn.2d 1011 (1973).1 A causal connection between intoxication and injury was required although a literal reading of the pre1983 statute would not have so required. Mearns, at 826. The 1983 amendments renamed the crime of negligent homicide in RCW 46.61.520, vehicular homicide. Laws of 1983, ch. 164, § 1, p. 719. The wording of the statute was also changed.2

[234]*234During the instruction conference here, the State objected to giving instructions 17, 18, and 19 involving rules of the road, not in issue here, on the basis they went to the issue of contributory negligence. The judge, in commenting on why he was giving these instructions, said:

the duty and burden is on the State to prove the causation and if there's an intervening cause. The example I've used is I'll use two examples, i.e., a person driving down the road admittedly drunk and a meteor hit somebody else, hits the rider riding with him, and the meteor kills the passenger, the question of causation becomes important. Second example, which is probably more in the real world, if a person is drunk driving down the road, going through a green-lighted intersection and the opponent or to the right of him comes through and totally runs the red light and hits him, then you would have an issue of causation as to the death. The fact that the legislature has said, in my view, that if you drive over, with a blood alcohol of over .10, there is an accident and as a result of that driving an accident the death ensues as a proximate cause thereof, then the Defendant is guilty of the crime. That's a change in what the history of the legislature and legislation has been and a change in the interpretation of the cases. It changed at the time that we went to the rule that over .10 you're guilty of driving while under the influence. It doesn't matter about the nature of the driving. That's what has been taken out. We don't have the question of negligent driving or reckless driving; it's assumed by the law, the legislature, that you are affected and contributed to the accident, I guess.

(Italics ours.) State v. Knowles, 46 Wn. App. 426, 430, 730 P.2d 738 (1986) had no difficulty requiring a showing that the defendant's intoxication proximately caused the accident. The court stated:

If the State prosecutes a case under the intoxication section of the vehicular homicide statute, it has the burden of proving that the defendant's intoxication "caused him [235]*235to operate his vehicle in an errant manner and that the affected driving caused the injury to the decedent."

(quoting Mearns, at 826). The trial judge was mistaken in his examples.

The court's instruction 5, to which Mr. MacMaster objected, provided in part:

To convict the defendant of the crime of vehicular homicide, each of the following elements of the crime must be proved beyond a reasonable doubt:
(1) That on or about the 22nd day of April, 1985, the defendant operated a motor vehicle;
(2) That at the time, the defendant:
(a) operated the motor vehicle and was under the influence of, or affected by intoxicating liquor, and thereby proximately caused injury to Rhonda Raber, or
(b) operated the motor vehicle in a reckless manner and thereby proximately caused injury to Rhonda Raber, or
(c) operated the motor vehicle with disregard for the safety of others and thereby proximately caused injury to Rhonda Raber;
(3) That Rhonda Raber died as a proximate result of the injuries; and
(4) That the injury occurred in Grant County, Washington.

(Italics ours.) Mr.

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Related

State v. Jones
821 P.2d 543 (Court of Appeals of Washington, 1992)
State v. Ransom
785 P.2d 469 (Court of Appeals of Washington, 1990)
State v. MacMaster
778 P.2d 1037 (Washington Supreme Court, 1989)
State v. Neher
759 P.2d 475 (Court of Appeals of Washington, 1988)
State v. MacMaster
752 P.2d 954 (Court of Appeals of Washington, 1988)

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Bluebook (online)
752 P.2d 954, 51 Wash. App. 231, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-macmaster-washctapp-1988.