In State v. Benoit, 650 A.2d 1230 (R.I. 1994), the defendant was driving in an extremely intoxicated state with his blood-alcohol content measuring .208, over twice the legal limit. Id. at 1231.
However, the evidence adduced at trial showed that it was the victims' car that "left its lane of travel, crossed either a dividing line and/or median strip, and made contact with the defendant's . . . truck . . . in the defendant's lane." Id.
Indeed, there was evidence that the intoxicated defendant tried to swerve and avoid the victims' oncoming car. Id. at 1234.
The ensuing accident seriously injured the driver of the other car and killed the passenger. The defendant was charged with DUI manslaughter and DUI causing seriously bodily injury. He moved to dismiss both counts on the grounds that the State could not prove that his operation of his automobile proximately caused the death and serious bodily injury of the victims. The trial judge granted the motion and dismissed both counts. Id. at 1231.
On appeal, the Rhode Island Supreme Court first determined that the DUI manslaughter statute contained a proximate cause element. Id. at 1233.
From there, the court found that in order for a valid conviction to be obtained, "the state must produce sufficient evidence for a jury to conclude that the defendant's manner of operating his or her motor vehicle was a proximate cause of the victim's death and the collision occurred while the defendant was legally intoxicated." Id.
However, the court noted that "this evidence need not necessarily show that the defendant's manner of operating his or her motor vehicle was either reckless or criminally negligent, as there is nothing in the statute to require this." Id.
The court made clear that the state did not have to prove that the defendant's intoxication was the proximate cause of the death, but only that "the defendant's operation of his or her motor vehicle was a proximate cause of the death in question occurring while the defendant was legally intoxicated." Id.
Under that reasoning, the court concluded that "there is scant evidence in the record other than his presence on the highway to show that the defendant's manner of driving was the proximate cause of the death and injury in question." Id. at 1234.
Consequently, the court affirmed the trial judge's dismissal of the charges. Id.