People v. Lardie was an instrumental case within Michigan law. It defined the parameters by which due process and mens rea interpretations could be extended in a criminal case. Throughout the course of the case, there were many facts, issues, and theories produced as to the veracity of the Michigan law that provided the sentencing guidelines for individuals who drove while intoxicated. However, no opinion mattered more than that of the Supreme Court of Michigan.
Within the opinion, delivered by the Supreme Court of Michigan, the facts were undisputed and hereto set forth as follows: On May 22, 1993 Mr. Lardie, hereinafter the respondent, hosted a party in his home, where he consumed alcohol and marijuana. At the time of consuming the barbiturates, the respondent was seventeen years of age. Around 1:00 a.m., of the night of the party, the respondent embarked in his vehicle, with three others, to provide transportation to the passenger’s vehicle.
During the course of the trip an accident too place, killing the respondent’s three passengers. Upon review of the physical evidence taken from the scene, it was concluded that the respondent had a blood-alcohol level of 0.12 percent or greater at the time of the accident, as well as positive test for marijuana use. The respondent was then charged with three counts of causing death by operating a vehicle, while under the influence of intoxicating liquor, in violation of MCL 257.625(4); MSA 9.2325(4).
The provisions within the statutes set forth each count to carry a maximum sentence of 15 years in prison for persons who operate a vehicle while intoxicated. The respondent moved to dismiss the charges, asserting the statute was in violation of his right to due process because it did not require proof of a criminal mindset or some form of negligence. The circuit court concurred and dismissed the counts against him. The people appealed the to the Michigan Court of Appeals, whereby the circuit court’s ruling was reversed. In turn, the respondent appealed the Court of Appeal’s decision to the Supreme Court of Michigan, where leave was granted and the appeal accepted.
The Supreme Court of Michigan affirmed the Court of Appeals holding.
ISSUES PRESENTED FOR CONSIDERATION
- Whether the application of MCL 257.625(4); MSA 9.2325(4) was erroneous, as it was applied to the respondent on the grounds the respondent possessed the mens rea/intent to commit the act.
- Whether the application of MCL 257.625(4); MSA 9.2325(4) was un-constitutional on due process grounds, as applied to the facts of the respondent’s case?
RULE OF LAW
“A person, whether licensed or not, who operates a motor vehicle upon a highway or other place open to the general public or generally accessible to motor vehicles, including an area designated for the parking of vehicles, within this state, under the influence of intoxicating liquor or a controlled substance, or a combination of intoxicating liquor and a controlled substance, or with a blood alcohol content of 0.10% or more by weight of alcohol, and by the operation of that motor vehicle causes the death of another person is guilty of a felony, punishable by imprisonment for not more than 15 years, or a fine of not less than $2,500.00 or more than $10,000.00, or both. [MCL 257.625(4); MSA 9.2325(4).].”
“Criminal intent is usually an element of a crime even where the crime is created by the statute.” People v. Rice, 161 Mich. 657, 664; 126 N.W. 981 (1910). “In order to determine whether a statute imposes strict liability or requires proof of a mens rea, that is, a guilty mind, this Court first examines the statute itself and seeks to determine the Legislature’s intent.” People v. Quinn, 440 Mich. 178, 185; 487 N.W.2d 194 (1992). “The United States Supreme Court has recognized that there are due process limitations on the state’s police power to impose a penalty for a violation of a law when a person charged with the crime did not have a criminal intent.” See Lambert v California, 355 U.S. 225, 228; 78 S Ct 240; 2 L Ed 2d 228 (1957).
In determining whether the court was in error when it applied the requirement for the respondent to possess a mens rea at the time of the accident, the Supreme Court used People v. Quinn, 440 Mich. 178, 185; 487 N.W.2d 194 (1992) as the standard of review. Quinn stipulates that, “In order to determine whether a statute imposes strict liability or requires proof of a mens rea, that is, a guilty mind, this Court first examines the statute itself and seeks to determine the Legislature’s intent.” Id.
When the court examined the stipulations set forth within [MCL 257.625(4); MSA 9.2325(4).] it held that the State’s Legislature has not expressly included language to show that fault was a necessary element of a crime. However, the Court also noted that it was their duty to determine what the Legislature’s intent was when the law was drafted, so that it could determine if some element of strict liability might have been at issue.
The court held the following, regarding strict liability crime versus a general intent crime:For a strict-liability crime, the people need only prove that the act was performed regardless of what the actor knew or did not know. Quinn, supra at 188. On this basis, the distinction between a strict-liability crime and a general-intent crime is that, for a general-intent crime, the people must prove that the defendant purposefully or voluntarily performed the wrongful act, whereas, for a strict-liability crime, the people merely need to prove that the defendant performed the wrongful act, irrespective of whether he intended to perform it. 452 Mich 231 at 241.
Since the statute the respondent was charged with violating was designed “to deter motorists from deciding to drive after they have become intoxicated” it went to reason that the Court erred on the side of the legislature in determining that the statute was unambiguous in that it sought to “punish the harm caused by intoxicated driving, not voluntary intoxication.” Furthermore, when examining the Constitutional due process grounds for dismissal, the Court cited Lambert v California, 355 U.S. 225, 228; 78 S Ct 240; 2 L Ed 2d 228 (1957) as the standard of review for examining due process issues.
In this case, the U.S. Supreme Court held, “that there are due process limitations on the state’s police power to impose a penalty for a violation of a law when a person charged with the crime did not have a criminal intent. However, since the statute cannot be interpreted as one of strict liability, any strict liability offense articulated as a defense cannot be raised, as it cannot apply to the Michigan statute. The Supreme Court of Michigan also held that though there were several questions raised, the lower court was in error when it granted the respondent’s motion to dismiss, as it was an issue of causation that needed to be presented to a jury and not just the court.
The court’s holding was one that eliminated the need for the People to prove gross negligence, a stipulation needed to prove strict liability, and instead made the issue of intent the linchpin for the People’s case to rest on. Showing the respondent possessed the mens rea to operate the vehicle while under the influence of alcohol would also show the respondent was in a culpable mental state and therefore liable for the deaths of the passengers, since he had the intent to drive the vehicle. Furthermore, the due process issue is mute since there is no strict liability at issue and the primary focus is intent.
(1996). People v. Lardie, 452 Mich 231, 551 N.W.2d 656 (1996). Retrieved December
18, 2007, from Lois Law Web site: http://loislaw.com/pns/index.htp.