City of Auburn v. Hedlund

Brief Fact Summary.

Hedlund was convicted as an accomplice to a DUI after she hosted a party where excessive drinking was caught on videotape and she sustained head injuries when she was injured by a drunk driver.

Synopsis of Rule of Law.

A person cannot be charged as an accomplice to a crime that the person was a victim of.

Facts.

Hedlund hosted a party where the guests were drinking in excess and a camcorder was being passed around to record the events that night. Hedlund’s mother ended the party and the guests were ordered to leave. Hedlund got in a vehicle with a person who had been drinking was behind the wheel; the events of the night were still being recorded. The driver crashed the car and the passengers in the car died, while Hedlund sustained serious head injuries. Hedlund was convicted as an accomplice to DUI and the court of appeals reversed. The City of Auburn appealed.

Issue.

Whether a person can be an accomplice to a crime to which he was a victim?

Held.

No. The decision of the appellate court is affirmed.

Dissent.

(Madsen, J.) The Washington statute that prevents a victim of a crime from being charged as an accomplice should be restricted to those crimes that bring injury to a person or their property. DUI is not a crime that requires that a person or property be injured, and the defendant therefore should not be precluded form being charged as an accomplice.

Discussion.

In the state of Washington, a person cannot be convicted of a crime to which the defendant is a victim. Hedlund, therefore, cannot be charged as an accomplice under the statute.