People v. Noble: What Does Reasonable Assistance After an Accident Mean?
In People v. Noble, the Michigan Court of Appeals discusses the law requiring a person to render aid following an accident.
From this case, we know a person involved in an accident in which a person is injured has an obligation to provide the person with reasonable assistance in securing medical treatment.
The Court in this case declined to decide that the provision requiring a person involved in an accident to provide reasonable assistance to an injured person is unconstitutionally vague.
Facts of the Case
Defendant Noble was convicted by a jury of failing to stop at the scene of a serious personal injury accident.
Noble was driving a truck with two passengers. Noble lost control of the vehicle, went of the road, and into the woods. One passenger suffered severe injuries to his face and neck.
Noble left the scene and went to a bar where he retrieved a tow truck, went back to the accident, and brought the truck and two passengers back to the bar. The passenger who suffered injuries later died. A bar employee call 911 when the three arrived, and Noble and the uninjured passenger left the bar.
After his conviction, Noble argued that the statute MCL 257.619 is unconstitutionally vague. Specifically, Noble’s argument is the law does not provide notice of what a person should do in that situation.
Rendering Aid When There is an Accident
MCL 257.619 states a driver of any vehicle who knows or who has reason to believe that he has been involved in an accident resulting in injury to or death of any person or damage to any vehicle which is driven or attended to by any person shall give his name, address, and the registration number of the vehicle he is driving, also the name and address of the owner, and exhibit his operator’s or chauffeur’s license to the person struck or the driver or occupants of any vehicle collided with and shall render to any person injured in such accident reasonable assistance in securing medical aid or transportation of injured person or persons.
The relevant section is the last sentence regarding the rendering of aid by a person involved in the accident.
The Court’s Decision
The Court first noted first a previous version of the law had been upheld on appeal. This version stated a driver must render to any person injured in such accident reasonable assistance including the carrying of such person to a physician or surgeon for medical or surgical treatment if it is apparent that such treatment is necessary or is requested by the injured person.
Noble distinguished that law from the current version by stating the earlier version was more definite than the current version. The Court disagreed because of the language “regarding reasonable assistance,” which allows a jury to employ a reasonable person standard in deciding what constitutes reasonable assistance. The Court noted the specific requirement that includes carrying a person to the doctor was not an exhaustive list of responsibilities.
The Court did not believe the statute was unconstitutionally vague as applied to Noble.
The Court reasoned, “defendant’s behavior could reasonably be construed as purposely avoiding the most immediate means of securing medical aid for Dalton (injured passenger).”
Defendant Argues Insufficient Evidence
On Appeal, Noble also argued there was insufficient evidence to convict him of failing to render reasonable assistance at a serious personal injury accident. The Court ruled against him here as well.
The Court reasoned that Noble’s actions could be construed as trying to relieve himself of culpability in the situation instead of providing reasonable assistance, possibly because he did not have a driver’s license.
Noble turned down an offer of help from a passing car. Noble also went to get a tow truck, which was a further distance away than a closer establishment where he could call for help. When getting the two truck, he did not call for help, but rather got the tow truck and went back to the scene of the accident himself. He told an employee at the establishment later to no call for help. Also, Noble left the bar where 911 was called before the ambulance arrived.
Takeaways From The Case
Persons involved in an accident in which a person is injured have an obligation to provide the injured person with reasonable assistance in securing medical treatment.
We don’t know exactly what the phrase “reasonable assistance” means. A jury gets to decide what reasonable assistance means. It would seem to means that a driver must take some affirmative steps to help an injured.
Of course, after an accident a driver should do everything possible to help an injured driver. This doesn’t mean the driver should try to perform surgery him or herself. But it means the driver should take affirmative steps within the driver’s power to ensure the injured driver is able to receive medical attention.
The leaving the scene of an accident laws are different than many criminal laws because the law actually imposes an affirmative duty on a person. Most criminal laws simply prohibit certain activities, such as you can’t use drugs or drive under the influence. However, this law tells us that drivers must take action.
These are difficult cases to judge because drivers are often frazzled after an accident, even if they are uninjured. What may seem reasonable to a person at the time could be judged harshly by a jury who is upset at the situation.
Call ArborYpsi Law
Sam Bernstein is a Criminal Attorney in Ann Arbor and Ypsilanti.
ArborYpsi Law is located at 4158 Washtenaw Ave., Ann Arbor, MI 48108.
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Have You Been Charged With Failure to Render Aid After an Accident?
ArborYpsi Law has experience representing clients on leaving the scene of accident cases. The leaving the scene crimes are complicated because, as noted above, these are some of the only criminal laws that impose obligations on a person to take affirmative actions. If you have been charged with one of these crimes call us to see how we can help.
We can sit down for an initial consultation to determine if we are the right attorneys for your case. A the consultation, we will discuss the law, options, a plan of action, and next steps.
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