People v. Decina

Brief Fact Summary.

Decina (defendant) was charged with criminal negligence after he crashed his vehicle while having an epileptic seizure, killing four.

Synopsis of Rule of Law.

A criminal defendant who disregards the consequences of a mental or physical condition, which has the possibility of producing certain involuntary actions, can be found guilty of vehicular homicide based on the consequences of those involuntary actions.

Facts.

Decina suffered from epilepsy and as a result had an epileptic seizure while he was driving his car. The seizure caused the car to speed up and hit a curb, which resulted in the car striking and killing four individuals. Decina was charged with criminal negligence while operating a motor vehicle and he appealed.

Issue.

Whether a defendant who ignores the consequences of a physical or mental condition that can produce involuntary actions while operating a vehicle can be found guilty of vehicular homicide resulting from those involuntary actions?

Held.

Yes. a defendant who ignores the consequences of a physical or mental condition that can produce involuntary actions while operating a motor vehicle can be found guilty of vehicular homicide resulting from those involuntary actions

Dissent.

The seizure was an involuntary act and the appellate court seems to think that the deaths were caused by reckless driving, but this can not be true since there was no affirmative voluntary act by Decina.

Concurrence.

The seizure was an involuntary act and the appellate court seems to think that the deaths were caused by reckless driving, but this can not be true since there was no affirmative voluntary act by Decina.

Discussion.

Decina knew that he was subject to these epileptic seizures and still decided to operate a vehicle, while knowing the condition may produce certain involuntary actions that could have adverse effects, such as loss of consciousness for a period of time. He knowingly undertook the responsibility of operating a motor vehicle, while knowing that the consequences may cause bodily harm or death to other persons on the road. His actions disregarded any possible consequences of an epileptic seizure which is sufficient to satisfy the first of the two elements of any crime i.e. actus reus. Decina had knowledge of his condition along with a disregard for any consequence resulting from the condition, which is sufficient for conduct for a charge of criminal negligence.