State v. Lamprey

Facts

D operated a child daycare center in her home. D would meet the school-age children in the afternoon at the bus stop where the school bus dropped them off, sometimes walking to the bus stop and other times driving her pickup truck. When D drove the truck, the children routinely rode back to her house in the truck bed. On one occasion not long before the accident, a parent saw children riding in the bed of D's truck and complained to her. D drove her truck to the bus stop and picked up six children. Three of the children were six years old and three were ten years old. All six children climbed into the bed. No child seats or safety belts were in place in the truck bed. The truck left the road and struck a tree. All six children suffered injuries, and one of the children, Katie Silva, died. P claims the accident occurred while D was driving so-called 'swervies' to entertain the children. D would steer the truck back and forth in a zigzag pattern. P introduced testimony from three children that D was doing swervies just before the accident, as well as testimony by police officers about tire marks they observed on the road leading to the site of the accident. P claimed that no mechanical problem with the truck contributed to the accident. D stated she did not remember doing swervies on the day of the accident but, if she did so, it was because there was a dog in the road. D claimed that a mechanical defect in the truck caused an unexpected acceleration resulting in the accident. The court instructed the jury: 

A legal cause of death and/or serious bodily injuries is a cause that is a direct and substantial factor in bringing about that death and/or injuries. It is not merely a possible cause or a contributing cause of death and a contributing cause of injuries. It must be the predominant cause without which the results would not have occurred. Because there can be more than one cause of death and/or injuries, the State does not have to prove that the defendant's conduct was the sole cause of the victim's death and/or injuries. However, the State does have to prove that the victim's death and/or injuries were a direct result of the defendant's actions; stated in a different way, that the defendant's conduct was a substantial factor in causing Katie Silva's death or the serious bodily injuries to the other children. The causal link required between the defendant's acts and the death and/or the serious bodily injuries is not proved if the intervening cause is the sole substantial cause of such death and/or injuries. The State must prove beyond a reasonable doubt that the acts of the defendant remain a substantial cause of the death and/or injuries. The element of causation is satisfied if the State proves beyond a reasonable doubt that the acts of the defendant remained the substantial cause of the death and/or injuries.

D was convicted and appealed. 

Issues

Rule of Law

Holding and Decision

Legal Analysis

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