State v. Hughes
In State v. Hughes, 80 Wash. App. 196, 907 P.2d 336 (Wash. App. 1995), the defendant was drag racing two friends in another car which left the highway and crashed, killing its two occupants. He fled the scene and anonymously reported the accident to the police by telephone. The defendant was convicted of violating a Washington statute obligating a driver "involved in an accident" to remain at the scene to provide aid and information and to report the accident. 907 P.2d at 337 n. 2.
He appealed, arguing that he did not fall within the ambit of the statute because there had been no physical contact between his vehicle and the car that had crashed.
The court emphasized that the legislature had chosen the broader phrase, "involved in an accident," in contrast to the narrower, "collides with a vehicle," and stated, "' Involved' is an imprecise term incorporating such concepts as being part of, contributing to and being a participant." 907 P.2d at 339.
The court found the evidence sufficient to support the defendant's conviction based on his being "' involved' in the accident." Id.