Sunday, November 17, 2013

State v. Munnell case brief

State v. Munnell case brief summary
344 N.W.2d 883 (1984)

The Itasca County District Court (Minnesota) certified four questions for review: (1) Is Minn. Stat. § 609.21, subd. 1 (1983), void for vagueness? (2) Is the statute overbroad, or does it deny equal protection? (3) Is the statute unconstitutional in effect and application to a defendant who is less at fault than the deceased victim? (4) Is being less at fault than the deceased victim a defense under the statute?

While traveling along a highway, defendant crossed the centerline, striking and killing decedent, who had been lying unconscious on the roadway. Blood alcohol tests revealed that both defendant and the victim were intoxicated, with defendant having a blood alcohol concentration of .11 percent and the victim having a blood alcohol concentration of at least .24 percent. Defendant was charged with criminal vehicular operation in violation of Minn. Stat. § 609.21, subd. 1 (1983). Defendant moved to dismiss, contending that the statute was vague and overbroad. After the trial court denied defendant's motion, it certified four questions for consideration.

  • On review, the court concluded that the statute was not impermissibly vague; use of the term "negligent" gave fair notice of the type of conduct prohibited. 
  • Further, defendant's overbreadth claim failed because she pointed to no constitutionally protected activity that the statute impinged upon. 
  • Defendant's equal protection claim likewise failed because the statute's singling out of drunk drivers was reasonably and rationally related to the purposes of the law. 
  • Lastly, the fault of the victim was not a defense under the statute.

The statute was not void for vagueness, was not overbroad, and did not deny equal protection. Further, a victim's contributory negligence was not a defense under Minn. Stat. § 609.21, subd. 1 (1983).

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