People v. Rideout
Court of Appeals of Michigan
727 N.W.2d 630 (2006)
While driving intoxicated, Rideout (defendant) collided with Jason Reichelt's car, which spun into the center of the road. Reichelt and his passenger, Jonathan Keiser, were uninjured and went to speak with Rideout at the roadside; worried about their own dark, unlit car sitting in the road, they returned to it, and Keiser was struck and killed by an oncoming vehicle. Rideout was convicted of causing death while driving intoxicated and appealed, challenging the causation instructions and the sufficiency of the evidence on proximate cause.
Whether a defendant's conduct can be the proximate cause of a victim's death when there is an intervening cause, such as the victim's own later decision that contributed to the injury.