Defendant's Conviction Reversed

Case: People v. Czuprynski

Court: Michigan Court of Appeals ( Published Opinion )

Issues:

Whether the provided jury instruction (M Crim JI 15.19) adequately informed the jury of what the statute requires for a defendant to have caused the serious impairment of a body function under MCL 257.601d(2); Statutory interpretation; People v. Schaefer; People v. Small; People v. Pinkney; Causation; People v. Feezel; Proximate cause; Harmless error; People v. Riddle; Henderson v. Kibbe; Unanimity; People v. Nicolaides; People v. Fullwood;People v. Goold; Claim that the jury should have been instructed that a conviction required a mens rea reflecting criminal culpability; People v. Pace; Validity of a search warrant; Probable cause; People v. Russo; People v. Mullen; Reasonable reliance on a warrant; People v. Goldston; United States v. Leon

Summary:

The court reversed defendant’s conviction and remanded for a new trial before a properly instructed jury. He was convicted by a jury of committing “a motor-vehicle moving violation and thereby causing a serious impairment of a body function” (MCL 257.601d(2)). Defendant argued that “M Crim JI 15.19, defining ‘moving violation causing serious impairment of a body function’ was erroneous.” He also argued that the trial court compounded the error in M Crim JI 15.19 in answering a jury question during deliberations, “when it again emphasized the erroneous portion of the instruction.” The court agreed. The issue was whether the jury instruction given “adequately informed the jury of what the statute requires for a defendant to have caused the serious impairment of a body function under MCL 257.601d(2).” The court held that “the statute requires that a moving violation together with the operation of a motor vehicle cause the serious impairment of a body function. Thus, the statute plainly requires a causal link between the moving violation and the injury, not simply a causal link between the operation of the vehicle and the injury.” The instruction given “relieved the prosecution of proving that the moving violation caused the accident and instead required only that ‘the operation of the motor vehicle’ caused the accident.” Thus, it created a de facto “strict liability offense in which any person who is involved in a serious injury accident and who has committed a moving violation is automatically guilty of the criminal offense charged here because, by definition in each case that crime is charged, there will have been an accident in which a defendant operated a motor vehicle.” The court also concluded that the error deprived defendant of a fair trial. “The jury was confused by the model instruction that was given.” Further, there was “strongly controverted evidence as to the cause of the accident.” Under the circumstances, defendant did not receive a fair trial on the causation issue.