People v. Rideout

Rideout (D) was intoxicated while driving and collided his SUV with Reichelt’s car, which came to a stop on the middle of the road as a result. Neither Reichelt nor his passenger Keiser were seriously injured. They left their car and got to the road margin, checked on Rideout and then, recognizing the danger that other cars could hit the unlit car, went back to the stopped car to see if they could turn on its flashers. While there beside the car, an oncoming vehicle hit Keiser, killing him. Rideout was convicted of driving while drunk or visibly impaired and thus causing death. During the jury trial the judge instructed the jury on causation-in-fact but not on proximate cause or superseding intervening causes. The instruction included the rule that one of several causes is taken to be a substantial cause of death if but for that cause death would not have happened, unless as a highly unnatural result of the original cause. The jury was also told that for a cause to be a superseding cause it must be the sole cause. Rideout argued that the court’s instructions to the jury were wrong. He claimed that he was not the proximate cause of Keiser’s death. He appealed, and was granted review by the intermediate court of appeals.