Jeffries v. State
Alaska Court of Appeals
90 P.3d 185 (2004)
Jeffries (defendant) killed another motorist while driving drunk, and his only specific reckless act during the crash itself — beyond simply being impaired — was one dangerous left turn. However, Jeffries had a long history of prior drunk-driving convictions, had repeatedly refused court-ordered treatment, and had had his license revoked for the past decade. He was convicted of second-degree murder and appealed, arguing that a single reckless turn while intoxicated wasn't enough to prove the extreme recklessness that distinguishes murder from manslaughter.
Whether, for a second-degree murder conviction, proof of the defendant's extreme recklessness may be established by conduct that occurred beyond the scope of the crime itself.