Justia Transportation Law Opinion Summaries

Randall J. Weddle was involved in a major motor vehicle accident in Washington, Maine, which resulted in the death of two drivers. The accident involved five vehicles, one of which was engulfed in flames. Weddle, the driver of a large tractor trailer, was found to be the cause of the accident. Hospital tests revealed that Weddle had alcohol in his system and officers found a three-quarters-full whiskey bottle and a shot glass in his truck several days after the accident.Weddle was charged with two counts of manslaughter, two counts of aggravated criminal operating under the influence, one count of causing injury while operating under the influence, one count of aggravated driving to endanger, one count of driving to endanger, and eight counts of violating commercial motor carrier operator rules. The jury found Weddle guilty of all counts. The court conducted a sentencing analysis and set the basic sentence at twenty years, considering the nature and circumstances of the crime. The court set the maximum sentence at thirty years, weighing mitigating and aggravating factors. The final sentence was set at thirty years, with all but twenty-five years suspended, followed by four years of probation.Weddle appealed his sentence to the Maine Supreme Judicial Court. He argued that his sentence was unconstitutional because it was not proportioned to the offense and that it was excessively harsh. The court affirmed the sentence, concluding that the sentence was not greatly disproportionate to the offense and did not offend prevailing notions of decency. The court also found that the sentence was not excessively harsh, as the court had considered both aggravating and mitigating factors in setting the maximum sentence. View "State of Maine v. Weddle" on Justia Law

The case involves the defendant, Kevin James Van Zanten, who was convicted for felony possession of methamphetamine and misdemeanor driving under the influence. Van Zanten challenged the conviction, arguing that the evidence was obtained unlawfully following a stop of the commercial vehicle he was driving. He claimed the stop was based on regulations adopted by the Idaho State Police, which he argued resulted from an unconstitutional delegation of legislative power.In September 2020, an Idaho State Police Trooper observed a 2005 Kenworth truck driven by Van Zanten. The Trooper noted several violations, including an improperly displayed Department of Transportation number, unsecured hazardous material, and other items on the truck. The truck was stopped, and the driver was identified as Van Zanten, whose driving privileges were found to be suspended. A subsequent search of the truck resulted in the finding of drugs, leading to Van Zanten's arrest.At the trial court, Van Zanten moved to suppress the evidence, arguing that the Trooper had no legal basis to stop him. He asserted that the Trooper initiated the stop to investigate state regulations that were unenforceable because the statutes authorizing those regulations unconstitutionally delegated legislative power. The district court denied his motion, leading to his appeal to the Idaho Supreme Court.The Supreme Court of the State of Idaho affirmed the district court's judgment. It held that the Trooper had reasonable suspicion to stop Van Zanten due to specific, articulable facts, thus justifying the stop. The court noted that the inherent danger associated with unsecured hazardous waste and other violations fell within the community caretaking function of law enforcement, and given the nature of the vehicle Van Zanten was driving, the public interest in safety outweighed the limited intrusion of stopping the vehicle. Consequently, the court did not need to address the constitutionality of the statutes in question. The court affirmed Van Zanten’s judgment of conviction. View "State v. Van Zanten" on Justia Law

In this case, the Supreme Court of Ohio was called upon to interpret the definition of "motor vehicle" as it applied to the crime of aggravated vehicular assault. The defendant, Joshua Fork, was charged with multiple counts, including aggravated vehicular assault, after driving a Polaris under the influence of alcohol and injuring his passengers. At issue was whether the Polaris should be classified as a "motor vehicle" or a "utility vehicle."The Court ruled that the definition of "motor vehicle" in R.C. 4501.01(B), which applies to penal laws, should be used in the context of aggravated vehicular assault. It also held that the Polaris should be classified as a "utility vehicle," as defined by R.C. 4501.01(VV), based on its principal purpose, not its use at the time of the incident.The Court reasoned that the principal purpose of the Polaris, as shown by evidence and testimony, was for farm-related activities, such as hauling rocks and bags of seed, removing limbs, pulling a sprayer, and trimming trees. The Polaris's ancillary use for recreation did not affect its principal purpose.The Court concluded that, since the Polaris fit the definition of a "utility vehicle" under R.C. 4501.01(VV), the evidence admitted at trial was legally insufficient to support Fork’s convictions for aggravated vehicular assault. Consequently, the Court affirmed the judgment of the Sixth District Court of Appeals, which had reversed the trial court's judgment and vacated Fork’s convictions for aggravated vehicular assault. View "State v. Fork" on Justia Law

In this case, the plaintiff, Anila Daulatzai, was removed from a Southwest Airlines flight after the captain received information about her dog allergy and the presence of two dogs on board. Daulatzai insisted on remaining in her seat despite the captain’s decision, leading to her physical removal by Maryland Transportation Authority police officers. She was later charged with various offenses, including disorderly conduct and resisting arrest.Daulatzai filed an action against Southwest Airlines and the State of Maryland, alleging various grounds to challenge her removal from the plane and her arrest. The district court dismissed Daulatzai’s complaint for failure to state a plausible claim upon which relief could be granted. Daulatzai appealed that judgment and, while her appeal was pending, she also filed a motion in the district court under Federal Rule of Civil Procedure 60(b), seeking to file a fourth version of her complaint with the district court.The court denied her request, finding that her efforts were pursued in bad faith, that her repeated failures to cure defects in her pleadings had been prejudicial to the defendants, and that the fourth complaint would, in any event, be futile. Daulatzai appealed that ruling as well.The United States Court of Appeals for the Fourth Circuit affirmed the district court's decision, finding that Daulatzai had failed to establish any of the grounds for relief under Rule 60(b) and that the district court did not abuse its discretion in denying Daulatzai leave to file her proposed third amended complaint. The court also found that Daulatzai had waived her challenge to the district court’s dismissal of her second amended complaint by failing to preserve it below. View "Daulatzai v. Maryland" on Justia Law

In December 2019, a taxicab driver, Phillip Palmer, shot a heavily intoxicated passenger, Nicholas Young, following a dispute over cab fare. The incident escalated into a physical altercation at a gas station, where Young shoved Palmer twice, causing him to fear for his life. Palmer, who had begun carrying a gun in his cab after hearing about a driver who had been shot by a passenger, fired two shots at Young, hitting him in the neck. Young survived his injuries. At trial, Palmer admitted to the shooting but claimed self-defense. The trial court denied Palmer's request for a self-defense jury instruction, finding Palmer's statements about his means of escape not credible and determining that a reasonable person would not have believed they were in danger of being killed by Young under the circumstances. Palmer was acquitted of attempted murder but found guilty of felonious assault and a firearm specification.The Supreme Court of Ohio reversed the decision of the Twelfth District Court of Appeals, which had affirmed the trial court's judgment. The Supreme Court determined that the trial court had improperly weighed the evidence when performing a sufficiency analysis. The court found that Palmer had presented legally sufficient evidence for each element of self-defense and was therefore entitled to a self-defense jury instruction. The evidence presented, if believed, could convince a trier of fact that Palmer was acting in self-defense. Therefore, the case was remanded for a new trial on the felonious-assault charge and accompanying firearm specification. View "State v. Palmer" on Justia Law

In Texas, the appellant was stopped by an officer for failing to remain in a single lane of traffic. After the officer smelled alcohol on the appellant's breath and observed signs of intoxication, he obtained a warrant for a blood sample, which showed a blood alcohol content of .174. The appellant was subsequently indicted for felony driving while intoxicated. The appellant filed a pre-trial motion to suppress, arguing that the officer did not have reasonable suspicion for the traffic stop. The trial court denied the motion, and the appellant was convicted. The appellant appealed, and the Third Court of Appeals reversed the conviction, holding that the stop was unlawful because the appellant's failure to maintain a single lane was not unsafe.The Court of Criminal Appeals of Texas considered whether a mistake of law should apply when an officer conducts a search or seizure under an ambiguous law. The court held that the officer's reasonable misinterpretation of the law did not undermine the reasonable suspicion required to conduct the traffic stop. The court noted that at the time of the stop, there was no controlling interpretation of the relevant section of the Texas transportation code from the Court of Criminal Appeals and the intermediate courts were split in their interpretations. The court therefore reversed the court of appeals' decision and affirmed the trial court's judgment. View "Daniel v. State" on Justia Law

In this case, Patrick Tvrdy was convicted of manslaughter and sentenced to 12 to 16 years' imprisonment following a vehicle-motorcycle collision that resulted in the death of the motorcycle driver, Brady Sweetser. Tvrdy appealed on three grounds: that the district court used erroneous jury instructions relating to motor vehicle homicide instead of manslaughter, that the evidence was insufficient to support his conviction, and that the sentence imposed was excessive.The Nebraska Supreme Court affirmed the district court's decision. The court found that the jury instructions correctly stated the law and were not misleading. The court noted that the law in Nebraska does not consider a victim's negligence as a defense to manslaughter unless that negligence is the sole proximate cause of the death. This principle was correctly reflected in the jury instructions.Regarding the sufficiency of the evidence, the court found that there was enough evidence to support Tvrdy's conviction. The court emphasized that an appellate court does not resolve conflicts in the evidence, pass on the credibility of witnesses, or reweigh the evidence. The court found that there was sufficient evidence of Tvrdy's intoxication and that there was never enough time for Tvrdy to complete his left turn without causing Sweetser, who had the right of way, to collide with him.As to the sentence, the court found no abuse of discretion by the district court. Tvrdy's sentence was within the statutory limits for his offense, and the court noted his criminal history of multiple speeding and possession of marijuana offenses, as well as a driving under the influence offense. View "State v. Tvrdy" on Justia Law

In Bowie County, Texas, Zimbabwe Raymond Johnson was involved in a car accident where he collided with a utility pole and an antique truck. He continued to drive away from the scene until his vehicle was no longer operational. Upon the arrival of the police, Johnson provided identification information but did not have insurance. Consequently, he was charged with failure to comply with duties to provide information after an accident and was convicted of attempting to commit those offenses. The trial judge imposed a $200 fine for each offense and ordered Johnson to pay restitution of $200 for the utility pole damage and $10,000 for the vehicle damage.On appeal, Johnson contested the restitution order, arguing that the offenses for which he was convicted did not cause the pole and truck damage. The court of appeals agreed and deleted the restitution awards. The State of Texas petitioned for a discretionary review of the decision by the Court of Criminal Appeals of Texas.The Court of Criminal Appeals of Texas affirmed the decision of the court of appeals. The court held that, under Article 42.037 of the Texas Code of Criminal Procedure, restitution could be ordered only when the offense for which the defendant was convicted caused the damage. The court stated that there was no evidence to suggest that Johnson's failure to comply with his duties of providing information after the accident caused any of the damage. Although the court acknowledged that in some situations, a failure to provide information could cause damage (such as by delaying necessary medical help), such was not the case here. The court dismissed the State's concern that limiting restitution might motivate overcharging just to obtain restitution, stating that such concern could not dictate the resolution of the issue. View "JOHNSON v. STATE OF TEXAS" on Justia Law

Appellant California Department of Motor Vehicles (DMV) appealed from a judgment granting Plaintiff’s petition for writ of mandate (judgment). DMV contends the issues presented on appeal are whether the trial court erred in overturning the suspension of Plaintiff’s driver’s license (1) “by applying [former] Government Code section 11440.30.   The Fifth Appellate District affirmed the “Judgment Granting Petition For Writ Of Mandate And Awarding Costs And Attorney Fees To Petitioner” and remanded the cause to the court below, with directions to modify the judgment to provide that the matter shall thereafter be remanded to the DMV for further proceedings. The court concluded that former Government Code section 11440.30 was applicable to Plaintiff’s DMV driver’s license suspension hearing. Said former statute is fully consistent with other relevant statutes, including, without limitation, Vehicle Code sections 14100 through 14112 and Government Code section 11501. Further, the court concluded that both CCR section 115.07 and former Government Code section 11440.30 were mandatory and not merely directory. Moreover, substantial evidence supports an implied finding that Plaintiff was prejudiced by DMV’s failure to adhere to former government code section 11440.30. View "Ramirez v. Super. Ct." on Justia Law

Defendant crashed his plane when he attempted to fly over Atigun Pass in the Brooks Range in Alaska. During both the investigation and Defendant’s appeal of the revocation of his airman certificate, Defendant claimed that the plane was climbing through 5,500 to 5,700 feet with a target altitude of 6,000 feet as it approached the pass. GPS data showed that the plane was flying at an altitude more than 1,000 feet lower than what Defendant claimed. The proceeding in Count One was the NTSB investigation. The proceeding in Count Two was the appeal before the NTSB of the FAA’s revocation of his airman certificate. Challenging his conviction on Count One, Defendant argued that the NTSB’s accident investigation was not a pending “proceeding” within the meaning of Section 1505.   The Ninth Circuit affirmed Defendant’s conviction on two counts of obstructing a pending proceeding and affirmed the district court’s assessment of a $5,000 fine. The panel wrote that even if it were not reviewing for plain error, it would affirm, holding that the NTSB’s investigation of Defendant’s plane crash was a “proceeding” within the meaning of Section 1505. The panel held that the district court did not err in instructing the jury on the materiality element. The panel held that the district court did not commit clear error in finding Defendant able to pay the $5,000 fine, as there was no evidence before the district court showing that Defendant was unable to pay the fine, or was likely become unable to pay it. View "USA V. FOREST KIRST" on Justia Law