In State v. Randol, 226 Kan. 347, 597 P.2d 672 (Kan. 1979), the Kansas Supreme Court addressed a vagueness challenge to the state's vehicular homicide statute, which addressed conduct that "creates an unreasonable risk of injury to the person or property of another and which constitutes a material deviation from the standard of care which a reasonable person would observe under the same circumstances." Id. at 675. The court stated that a "material deviation" from the standard of care required "something more than ordinary or simple negligence yet something less than gross and wanton negligence." Id. at 676. Noting that the latter two terms "have been ingrained in our law for years and are now generally accepted and understood," it found that the statute creating a new, intermediate standard based on a "material deviation," which was the same as a "substantial deviation," was not unconstitutionally vague. Id. at 676-77.