People v. Rideout
727 N.W.2d 630 (2006), 272 Mich. App. 602 (2006)
Rule of Law:
A defendant's conduct is not the proximate cause of a victim's death when the victim, after reaching a position of apparent safety following the defendant's initial act, makes a free and deliberate choice to return to a dangerous situation. This voluntary act constitutes a superseding intervening cause that breaks the chain of causation.
Facts:
- At 2:00 a.m., defendant Rideout, while driving with a blood alcohol concentration of 0.16, turned his SUV into the path of an oncoming car driven by Jason Reichelt.
- The collision disabled Reichelt's car, leaving it without headlights in the center of the road.
- Reichelt and his passenger, Jonathan Keiser, were not seriously injured and exited their vehicle.
- Both men walked to the side of the road, a position of safety, and spoke with Rideout.
- Reichelt and Keiser then voluntarily walked back to their disabled car on the dark roadway to try to turn on the hazard lights.
- While standing by the disabled car, an oncoming vehicle driven by Tonya Welch struck and killed Keiser.
Procedural Posture:
- Defendant Rideout was charged with operating a motor vehicle while intoxicated and thereby causing death.
- Following a trial in the Kent County Circuit Court (a trial court), a jury convicted Rideout as charged.
- The trial court sentenced Rideout to 3 to 15 years in prison.
- Rideout (the appellant) appealed his conviction to the Michigan Court of Appeals (an intermediate appellate court).
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Issue:
Does a drunk driver's conduct remain the proximate cause of a death when the victim, after initially reaching a place of safety following the first collision, voluntarily returns to the roadway and is subsequently struck and killed by a third party's vehicle?
Opinions:
Majority - Sawyer, P.J.
No. The drunk driver's conduct is not the proximate cause of the death because the victim's voluntary decision to leave a position of apparent safety and re-enter the roadway constitutes a superseding intervening cause. While Rideout's drunk driving was the factual 'but-for' cause of the events, legal or proximate cause was severed. The court applied two key doctrines to find the causal chain was broken. First, under the 'apparent-safety doctrine,' Rideout's active force came to rest when Keiser reached a position of safety on the side of the road. Second, Keiser's 'free, deliberate, and informed' decision to re-enter the dangerous roadway was a 'voluntary human intervention' that shifted legal responsibility from Rideout. Because Keiser reached safety and then chose to place himself back in peril, his death was not a direct and natural result of Rideout's actions.
Analysis:
This decision refines the concept of proximate cause in criminal law by emphasizing that a victim's own volitional acts can sever the causal link to a defendant's original wrongdoing, even when the defendant is the 'but-for' cause. It gives significant weight to the apparent-safety doctrine and the principle of voluntary human intervention, thereby limiting a defendant's liability for remote or attenuated consequences. The case establishes a strong precedent that in multi-event scenarios, courts must scrutinize whether the victim had reached a point of safety before the subsequent harm occurred. This provides a clearer line for when a defendant's legal responsibility ends and another person's begins.
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