AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

• The case involves an incident where the Defendant, while driving, encountered a group of cyclists traveling in the same direction on a two-lane highway. After passing the cyclists, the Defendant stopped his car and reversed towards them. During this event, the second cyclist in line lost control, crashed, and sustained severe injuries. The circumstances leading to the cyclist's injuries were disputed at trial, with varying accounts of whether the Defendant's car made contact with the cyclist (paras 3-5).

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Defendant-Appellant: Argued that the district court erred by not instructing the jury on proximate cause, improperly admitted lapel camera footage, violated his right to effective assistance of counsel by not requesting a duress instruction, his convictions violated double jeopardy, and the court failed to properly support its designation of his conviction as a serious violent offense (para 1).
• Plaintiff-Appellee: Opposed the Defendant's request for a jury instruction on proximate cause, arguing that the Defendant's actions were the proximate cause of the victim's injuries regardless of the specific interactions between the Defendant's car and the cyclists (para 6).

Legal Issues

• Whether the district court committed reversible error by denying the Defendant’s request for a jury instruction on proximate cause.
• Whether admitting lapel camera footage of a witness’s statement without qualifying the witness as an expert was plain error.
• Whether the Defendant’s right to effective assistance of counsel was violated due to the failure to request a duress instruction.
• Whether the Defendant’s convictions for both reckless driving and great bodily harm by vehicle violate double jeopardy.
• Whether the district court failed to make necessary findings to support its designation of the Defendant’s conviction as a serious violent offense.

Disposition

• The court reversed the conviction for great bodily injury by vehicle (reckless driving) and remanded for a new trial on that charge due to reversible error in refusing the Defendant’s requested instruction on proximate cause.
• Affirmed the conviction for reckless driving, finding no plain error in the admission of the lapel camera footage.
• Declined to reach the merits of the Defendant’s argument regarding ineffective assistance of counsel and the issue of double jeopardy (para 2).

Reasons

• IVES, Judge (J. MILES HANISEE, Chief Judge, and MEGAN P. DUFFY, Judge concurring): Found that the district court committed reversible error by not instructing the jury on proximate cause as a reasonable jury could have found that the Defendant’s actions were not the proximate cause of the victim’s injuries (paras 8-11). Determined that the admission of the lapel camera footage, even if erroneous, did not constitute plain error affecting the verdict's validity (paras 12-13). The court did not address the Defendant’s claim of ineffective assistance of counsel due to the argument being underdeveloped, particularly regarding whether the Defendant was prejudiced by the alleged deficient performance (paras 14-16). The court agreed with the State’s concession that convicting the Defendant of both reckless driving and great bodily harm by vehicle violated the constitutional prohibition against double jeopardy but did not make a formal ruling on this issue due to the case's remand for a new trial (para 2).