Can You Be Charged with Both Vehicular Homicide and DUI Manslaughter at the Same Time?
This is an important question under Florida law. The defendant, Alex D. Goodwin, was convicted of both vehicular homicide and DUI manslaughter stemming from a single fatal incident. These are two very serious crimes that come with mandatory minimum prison time. In the case of Goodwin, the state charged and convicted the defendant of both vehicular homicide and DUI manslaughter. Goodwin appealed the decision, and the matter made it all the way to the Florida Supreme Court. In this article, the Orlando, FL, DUI lawyers at FL DUI Group will discuss this case and how it applies to Florida laws regarding DUI.
Understanding the appeal
Goodwin was convicted on both charges (DUI manslaughter and vehicular homicide). He appealed the decision to the Fourth District Court of Appeal, which upheld the trial court’s judgment. Goodwin appealed again, and this time, the Florida Supreme Court took on the case. Ultimately, the Florida Supreme Court held that both offenses are aggravated forms of the same core offense (manslaughter) and differentiated only by degree under Florida Statutes § 775.021(4)(b)2.
Since they’re only degrees of the same crime, dual convictions and sentences are barred, since they violate double jeopardy protections. This ruling disapproved conflicting precedent (Murphy v. State) and remanded the case for further proceedings consistent with the Goodwin decision.
Why the Goodwin decision is important
- Double jeopardy safeguard – The decision ensures that criminal defendants cannot face multiple punishments for the same underlying homicide. In other words, one death cannot result in separate DUI convictions.
- Statutory clarity – The Goodwin case clarified that under § 775.021(4)(b)2, offenses that are merely degree variants of the same crime cannot result in multiple convictions.
- Authority – Despite shifts in related doctrines like the “single homicide rule,” Goodwin remains a binding precedent, reaffirmed even after later Supreme Court rulings.
The state can still charge you with multiple crimes
Sometimes, you’ll see an article in the newspaper that references an individual who is charged with both DUI manslaughter and vehicular homicide. The police can still charge you with both crimes, but you can only be convicted of one. In many cases, police can’t be 100% sure that a defendant was intoxicated at the time they caused an accident. In these cases, the police can file both charges against the defendant and wait for the tox screen to come in. If the tox screen says that they were under the influence at the time of the accident, then the state can proceed with DUI manslaughter charges. If it doesn’t, then the state can file vehicular manslaughter charges. Hence why some defendants face both charges at the same time. However, they can’t be convicted of both charges thanks to Goodwin.
Talk to an Orlando, FL, DUI Lawyer Today
FL DUI Group represents the interests of Orlando residents who have been charged with DUI. Call our Florida DUI defense lawyers today to schedule an appointment, and we can begin preparing your defense right away.
Source:
law.justia.com/cases/florida/fourth-district-court-of-appeal/2010/4d09-3390-op.html
