State v. Iten
1987 Minn. App. LEXIS 4099, 401 N.W.2d 127 (1987)
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Rule of Law:
A driver's failure to inspect their vehicle as required by law and their conscious decision to run a red light, despite having sufficient time to stop, constitutes gross negligence for a criminal vehicular operation charge. The victim's potential contributory negligence is not a defense to the criminal charge.
Facts:
- Raymond Iten was driving a truck and did not perform a pre-trip brake inspection, as required by federal and state regulations, because he was in a hurry.
- The truck's brakes were later found to be operating at only 50% effectiveness due to rust and oil deposits.
- As Iten approached the intersection with South Shore Drive, he saw the traffic light turn yellow from approximately 600 feet away and then red from approximately 320 feet away.
- Despite evidence showing he had sufficient time to bring the truck to a safe stop even with the impaired brakes, Iten decided not to stop.
- Iten honked his horn and entered the intersection against the red light.
- Iten saw Marna Quamstrom's car entering the intersection and swerved into the left lane to avoid her, but his truck's right front bumper struck her car.
- Quamstrom was ejected from her car, and the truck's rear dual wheels ran over her, causing instant death.
- Iten stopped the truck immediately after the collision and remained at the scene.
Procedural Posture:
- A grand jury indicted Raymond Iten on the charge of criminal vehicular operation resulting in death.
- Iten moved to dismiss the indictment in the trial court, but the motion was denied.
- The case proceeded to a jury trial in a Minnesota trial court.
- The jury found Iten guilty as charged, and the court entered a judgment of conviction.
- Iten (appellant) appealed the judgment to the Minnesota Court of Appeals.
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Issue:
Does a driver operate a vehicle in a grossly negligent manner when they fail to inspect its brakes as required by law and knowingly drive through a red light, even if they attempt last-second evasive maneuvers to avoid a collision?
Opinions:
Majority - Nierengarten, J.
Yes. A driver operates a vehicle in a grossly negligent manner under these circumstances. Gross negligence is defined as 'the want of even scant care.' The court found that Iten displayed this lack of care not in his last-second evasive maneuvers, but in his earlier actions: failing to inspect the truck's brakes as required by law and making the conscious decision to run a red light when he had more than sufficient time to stop safely. Iten's subjective belief that he could not stop safely was contradicted by the evidence. The court also held that evidence of the victim's failure to wear a seatbelt was irrelevant, as contributory negligence is not a defense to a criminal prosecution unless it constitutes a superseding intervening cause of the accident.
Analysis:
This case clarifies the standard for 'gross negligence' in the context of criminal vehicular operation. The court's analysis demonstrates that the defendant's entire course of conduct, including pre-operation safety failures and conscious violation of traffic laws, can establish the requisite level of negligence, not just the actions taken in the moments immediately preceding the collision. This decision reinforces that a defendant's last-second attempts to avoid a crash do not negate prior acts of gross negligence. It also solidifies the legal principle that a victim's contributory negligence is not a valid defense in a criminal prosecution in Minnesota.
