People v. Oliver: What it Means to be Involved in an Accident For Leaving the Scene of an Accident
In the case of People v. Ricky Dean Oliver, the Court discusses what it means to be “involved in” an accident for the purposes of leaving the scene of an accident law.
What Happened in the Case
Defendant Ricky Dean Oliver went to jury trial on charges of involuntary manslaughter, negligent operation of a vehicle causing homicide, and leaving the scene of an accident causing serious injury.
The jury acquitted Oliver of the first two charges and convicted him of leaving the scene of an accident causing serious injury. Oliver was sentenced to 3 to 5 years of imprisonment.
The case started with a fatal accident that took place in Cass County. Oliver was driving a Jeep and was playing a sort of game with his friend Bill Alexander who was driving a Honda.
Oliver used his Jeep to push the Honda down the road. The Jeep did not continuously push the Honda, but rather would push the Honda, which then coasted down the road, and then the Jeep would push the Honda again. During this, the Honda lost control, swerved to the right of the road, and then veered into in oncoming lane, striking a vehicle and killing the vehicle’s driver.
An accident reconstructionist testified the Honda would have been going 57 miles per hour at the time the Honda lost control.
After the accident, Oliver stopped on the right side of the highway, looked out the window toward the accident, and drove away. Oliver proceeded to a friend’s house where he hid the Jeep. Alexander (Honda driver) ran into the woods near the accident.
Oliver’s main argument on appeal was the prosecutor failed to prove beyond a reasonable doubt that he was guilty of leaving the scene of a serious injury accident.
Specifically, Oliver argued he was not “involved in” the accident because his Jeep was not in contact with the Honda when the Honda swerved onto the shoulder and the into the other lane and struck the deceased driver’s vehicle.
The Court looked up the term “involved” in the dictionary, and found the meaning to include “implicated.”
The Court rejected the argument. The Court reasoned the defendant “clearly played a part in the accident despite the fact his vehicle did not strike or come into contact with another vehicle.”
The evidence, the Court held, demonstrated that Oliver was implicated in or connected with the accident in a logical or substantial manner.
At trial, the prosecution presented evidence that Oliver’s Jeep pushed the Honda, which could not run of its own power, at about 57 miles per hour.
Leaving the Scene of an Accident Causing Serious Injury or Death Law
Michigan statute MCL 257.617 provides The driver of a vehicle who knows or who has reason to believe that he or she has been involved in an accident upon public or private property that is open to travel by the public shall immediately stop his or her vehicle at the scene of the accident and shall remain there until the requirements of section 619 are fulfilled or immediately report the accident to the nearest or most convenient police agency or officer to fulfill the requirements of section 619(a) and (b) if there is a reasonable and honest belief that remaining at the scene will result in further harm. The stop shall be made without obstructing traffic more than is necessary.
Leaving the scene of an accident resulting in the serious impairment or death of another person is a felony, punishable by up to 5 years in prison, a $5,000, or both.
Leaving the scene of an accident resulting in death of another person and where the defendant caused the accident is a felony, punishable by up to 15 years in prison, a $15,000, or both.
MCL 257.619 mentioned in the statute above provides person who knows or has reason to believe he was involved in an accident must give his name, address, and registration number of the vehicle he is driving, and show his driver’s license to a police officer or the person struck or the driver or occupants of any vehicle the driver collided with, and render to any person injured in such accident reasonable assistance in securing medical aid or transportation of injured persons.
It should be noted that the wording of the statute above reflects MCL 257.617 at the present date. At the time the case was decided, the statute MCL 257.617 substantially similar to the above language. However, the statute was worded differently and the potential punishments were different.
The Takeaway from the Case
There are a few takeaways from this case regarding what it means to be ‘involved in’ an accident. A driver does not need to be in direct physical contact with another vehicle to be involved in an accident. Also, a driver does not need to have caused an accident to be involved in an accident.
Sam Bernstein is a Criminal Defense Lawyer in Ypsilanti and Ann Arbor.
ArborYpsi Law is located at 4158 Washtenaw Ave., Ann Arbor, MI 48108