People v. Goodin: Does the Requirement to Stop After an Accident and Provide Information Violate the Right against Self-Incrimination?
The Court of Appeals in People v. Goodin ruled that the law requiring a person to stop at an accident and provide information does not violate the right against self-incrimination.
What Happened in the Case
Defendant Justin Goodin was convicted by a jury of failing to stop at the scene of an accident resulting in serious injury or death of a person and negligent operation of a vehicle causing homicide.
Goodin was involved in a road rage incident which resulted in the death of another driver. Both drivers took turns passing each other on the road. Goodin had to brake suddenly, causing the other driver to lose control, and roll over several times. Goodin did not stop at the accident, but continued driving away.
Legal Argument on Appeal
Goodin argued on appeal that charging him with both failure to stop at the scene of an accident and negligent homicide violated his constitutional right against self-incrimination. The argument goes that had he stopped to provide information, he would have incriminated himself as to the charge of negligent operation of a vehicle because that would be an admission he was at the scene of a crime.
Michigan law under MCL 257.619 requires a person involved in an accident to stop and do several things.
The person must give his or her name and address, and the registration number of the vehicle he or she is operating, including the name and address of the owner, to a police officer, the individual struck, or the driver or occupants of the vehicle with which he or she has collided.
The person must exhibit his or her operator’s or chauffeur’s license to a police officer, individual struck, or the driver or occupants of the vehicle with which he or she has collided.
And finally, a person must render to any individual injured in the accident reasonable assistance in securing medical aid or arrange for or provide transportation to any injured individual.
The Court’s Decision
The Court looked to the U.S. Supreme Court decision of California v. Byers for insight. In Byers, the Court said that “in order to invoke the privilege against compelled self-incrimination, the compelled disclosures must, in and of themselves, confront the claimant with “substantial hazards of self-incrimination.”
Here, the law just requires a person to give neutral information, such as name and address. The disclosure of this information are aimed at the public at large, and not a select group of inherently suspect of criminal activities. There is no implication in criminal conduct, as driving is a lawful activity and the reporting requirements, such as in MCL 257.619 are regulatory in nature.
The Court in the end upheld the conviction.
Sam Bernstein is a Defense Attorney in Ann Arbor and Ypsilanti.
ArborYpsi Law is located at 4158 Wasthenaw Ave., Ann Arbor, MI 48108
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