Davis v. State (1984)
In Davis v. State, 684 P.2d 147 (Alaska App. 1984), the State argued that seemingly inconsistent jury verdicts might hypothetically be reconciled. The Court rejected the State's argument because the State's suggested interpretation of the jury's verdicts, while hypothetically possible, was not reasonable in light of the record.
The defendant in Davis was convicted of criminally negligent homicide and reckless endangerment after his car collided with a pickup truck, injuring the driver and killing the passenger. Davis was convicted of criminally negligent homicide for causing the death of the passenger, but he was acquitted of assault for injuring the driver. Davis challenged the verdicts as inconsistent, arguing, inter alia, that the jury's finding that he caused the passenger's death was inconsistent with its finding that he did not cause the driver's injuries.
The State attempted to reconcile the verdicts by suggesting that the jury might have concluded that the driver was not injured, or that Davis had not employed a dangerous instrument when causing the driver's injuries.
The Court rejected the State's suggestions. The Court noted that it was undisputed at trial that the driver suffered substantial injuries. The Court further noted that, given the jury's verdict that Davis was guilty of criminally negligent homicide for causing the death of the passenger, it would have been irrational for the jury to conclude that Davis's car was not a dangerous instrument.