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Arizona Court Issues Ruling Regarding Admissibility of Victim’s Misconduct in Recent Manslaughter Case

Last month, a state appellate court issued a written opinion in an Arizona manslaughter case discussing the government’s contention that the lower court improperly admitted certain evidence regarding the victim’s conduct in the moments leading up to a fatal traffic accident. Ultimately, the court concluded that the victim’s actions were not a superseding cause of the accident, and thus the evidence at issue was not admissible.

The Facts of the Case

According to the court’s opinion, the defendant was driving well over the speed limit when he struck the rear-end of another vehicle that was making a left turn. Neither the driver of the other vehicle, nor his seven-month-old son, were properly restrained, and both were ejected from the car. The driver was seriously injured, and his son died. Officers found a marijuana pipe in the car, and the driver later tested positive for THC.

In a pre-trial motion, the prosecution asked the court to prevent the defendant from pursuing a superseding-cause theory and admitting evidence of the victim’s possible impairment. The prosecution also argued that evidence suggesting the victim failed to yield when making the left-turn was admissible, but that, as a matter of law, it was not a superseding cause of the accident.

The trial court denied the prosecution’s motion. Thus, under the trial court’s rulings, the defendant would have been able to present all the contested evidence to the jury and argue that the victim’s actions were a superseding cause of the accident, negating the defendant’s criminal liability. The prosecution appealed.

The Appellate Court’s Decision

On appeal, the court held that the lower court came to the wrong legal conclusion, and that the evidence was inadmissible. The court explained that in a criminal case, the prosecution must prove both but-for and proximate cause. However, the court went on to note that “a defendant’s actions need not be the sole cause of harm for the defendant to be held criminally liable.” The court explained that an event must be “unforeseeable and abnormal or extraordinary” to constitute a superseding cause.

Here, the court acknowledged that the victim’s actions may have increased the chances of a fatal accident, but it was the defendant’s actions that both started the wheels in motion and caused the ultimate harm. Thus, while the victim’s conduct may have increased the likelihood of an accident, his conduct did not constitute a superseding cause. As a result of the court’s decision, all contested evidence was precluded from the jury’s consideration.

Have You Been Arrested for an Arizona Manslaughter Crime?

If you have recently been arrested for an Arizona vehicular manslaughter crime, contact the Law Offices of James E. Novak for immediate assistance. Attorney Novak is an experienced Tempe criminal defense attorney dedicated to aggressively representing the interests of his clients. He routinely negotiates favorable plea agreements for his clients and will not hesitate to take a case to trial if the prosecution is unwilling to agree to a fair resolution. To learn more, and to schedule a free consultation today, call 480-413-1499 today.

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