People v. Rideout case brief (193 Ill. App.3d 884)

People v. Rideout

193 Ill. App.3d 884 (1990)
550 N.E.2d 632

Facts	-D was driving his car at 2:00 a.m. when he attempted to turn, drove into the path of oncoming car, which hit P’s car.  -It was determined that Def. had twice legal limit of blood alcohol content. -The driver (Reichelt) and passenger (Keiser) were not seriously injured. -The headlights stopped working. -Reichelt went to turn on flashers, when an oncoming car driven by Welch, hit Keiser, killing him.
Procedural History	N/A
Issue	Was there insufficient evidence of causation to establish D’s guilt?
Holding	Yes, the prosecution failed to present sufficient evidence to establish that D’s actions were a proximate cause of Keiser’s death.
Rules	Causation: 1. factual cause, 2. proximate cause. -Factual causation alone will not support imposition of criminal liability. Proximate cause must also be established. Proximate cause designed to prevent criminal liability from attaching when the result of the Def.’s conduct is viewed as too remote/unnatural. -For a D’s conduct to be regarded as a proximate cause, the victim’s injury must be a “direct and natural result” of the Def.’s actions. In making this determination it is necessary to: 1. examine whether there was an intervening cause that superseded the Def.’s conduct such that the causal link b/t the def.’s conduct and the victim’s injury was broken. 2. If an intervening cause did indeed supersede the def.’s act as a legally significant causal factor, then the def.’s conduct will not be deemed a proximate cause of the victim’s injury. Standard = reasonable foreseeability. (is the intervening cause foreseeable based on an objective standard of reasonableness?)
Analysis	The second accident only occurred after Keiser had reached the position of safety, and then chose to reenter the roadway. [Three of Six Factors to consider in determining in an intervening cause is a superseding cause.] 1. De minimis contribution to social harm factor. 2. The intended-consequences doctrine. 3. Omissions factor. Apparent safety factor: When a defendants active force has come to rest in a position of apparent safety, the court will follow it no longer. If accident had occurred before Keiser could get to side of the road, then causal chain would have been intact.

Link to Case:  People v. Rideout

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