Fatal Truck Ejection Was no Crash, Court Rules

(CN) — Spelling the reversal of a hit-and-run conviction, the Florida Supreme Court found that a driver whose passenger vaulted out of his vehicle and suffered fatal injuries cannot be said to have "crashed."

Jacob Gaulden had been convicted of leaving the scene of a crash, resulting in a person's death, in connection to a ride he gave on Dec. 19, 2010.

Gaulden, 26 at the time, picked up 22-year-old Christopher Holland outside a chicken stand on the far-west of the Florida Panhandle.

They made it only 10 minutes before an argument purportedly caused Holland to bail out of the moving vehicle.

Gaulden later professed that he drove away thinking Holland had not suffered serious harm, but Holland's fractured skull and other injuries were consistent with tumbling across the surface of the road.

The state charged Gaulden under Section 316.027, which says a driver "involved in a crash ... that results in injury of any person must immediately stop the vehicle at the scene of the crash or as close thereto as possible."

Violations of that law are punishable by a third-degree felony if the driver leaves the scene of a crash causing injury, and a first-degree felony if the driver leaves the scene of a crash causing death.

Gaulden argued in part that the charge against him should be dismissed on the grounds that he was not "involved in a crash" per the statutory wording.

Though a trial court in Escambia County agreed, a state appeals court reversed, and Gaulden was found guilty after a trial.

The First District Court of Appeal affirmed in 2014, but asked the Florida Supreme Court to resolve a question of "great public importance."

That question asks: "When a passenger separates from a moving vehicle and collides with the roadway or adjacent pavement, but the vehicle has no physical contact either with the passenger after the passenger's exit, or with any other vehicle, person or object, is the vehicle 'involved in a crash' so that the driver may be held criminally responsible for leaving the scene?"

The Florida Supreme Court answered no last week, setting the stage for a reversal of Gaulden's convicton.

"We hold that the operative phrase 'any vehicle involved in a crash' means that a vehicle must collide with another vehicle, person, or object," the unsigned opinion states. "Plainly, under the undisputed facts of this case, no vehicle was involved in a collision within the meaning of the statute. Accordingly, we answer the certified question in the negative, quash the district court's decision, and remand ... to the district court for application of our decision."

The lead opinion accuses the lower appeals court adopting an "expanded interpretation" to uphold Gaulden's conviction.

State lawmakers altered the statute's phrasing in a manner that had direct bearing on Gaulden's case back in 1999, according to the ruling, which notes that the statutory wording "involved in an accident" was changed to "involved in a crash," thereby narrowing the range of incidents covered by the law.

Though the July 7 ruling was unanimous, Chief Justice Charles Canady penned a brief concurring opinion joined by Justice Ricky Polston.

They specified that they would not rely on legislative history to arrive at the decision.

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