Law School Case Brief
People v. Lardie - 452 Mich. 231, 551 N.W.2d 656 (1996)
Specific intent is defined as a particular criminal intent beyond the act done, whereas general intent is merely the intent to perform the physical act itself. 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. 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.
On May 22, 1993, defendant Jash Eli Lardie drank alcohol and smoked marijuana at a party at his parents' home. He left his home at approximately 1:50 a.m. to give several people from the party a ride to one of their cars. From the physical evidence, Lardie apparently drove the car off the paved road and traveled about 130 feet on the shoulder. The car hit a small tree and then, traveling another 60-70 feet, struck a larger one, killing the three passengers in the back seat. Lardie had an estimated blood-alcohol level of 0.12 percent or greater at the time of the accident and tested positive for marijuana use. The People charged Lardie with three counts of causing death by operating a vehicle under the influence of intoxicating liquor. At trial in Michigan state court, Lardie filed a motion to dismiss the charges, claiming that the statute, Mich. Comp. Laws § 257.625(4), violated his right to due process because it did not require proof of either a mens rea or some form of negligence. The circuit court dismissed the counts against Lardie because it concluded that the statute was unconstitutional. On appeal, the appellate court reversed the circuit court's decision and concluded that the statute was constitutional. Lardie was granted leave to appeal.
In a separate action, defendant Gerald Daniel Hudick was driving a truck on in the right-hand lane of a highway at 1:30 a.m. William Wienclaw, a pedestrian, was intoxicated and was standing in the right lane in the dark when Hudick struck him with his vehicle and killed him. At 2:45 a.m., Hudick had a blood-alcohol level of 0.13 percent. Another driver testified at the preliminary examination that she was driving on the road at the same time and did not see Wienclaw until she was about 60-70 feet away from him. The People charged Hudick with involuntary manslaughter with a motor vehicle and, under MCL § 257.625(4); MSA § 9.2325(4), with causing death by operating a vehicle while intoxicated. At the preliminary examination, defendant argued that the statute was unconstitutional, claiming that it denied him due process by eliminating the need for finding a mens rea. The district court rejected the argument. The court of appeals denied Hudick leave to appeal. Hudick applied for leave to appeal in the Supreme Court of Michigan, which was granted to hear his case with the Lardie case.
Did Mich. Comp. Laws § 257.625(4) violate defendants' right to due process for not requiring proof of either a mens rea or some form of negligence before defendant could be convicted of the crime charged?
The state supreme court affirm the court of appeals decision in Lardie's case, which concluded that the statute was constitutional; the court affirmed the court of appeals' order in Hudick's case, which refused to grant him leave to appeal after the trial court approved the statute's constitutionality. The court held that the statute did not violate defendants' due process rights and that the statute was constitutional. The court found that the statute was similar to common-law involuntary manslaughter, except that it eliminated the People's need to prove gross negligence. By doing so, the legislature instead required that the People prove that defendants had a general intent to commit the wrongful act of drinking and driving. Thus, the statute did not impose strict liability. Moreover, the court averred that the statute required that the culpable mental state, the mens rea, have a causal relation to the harm that the statute sought to prevent.
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