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Jeffries v. State
Alaska Court of Appeals
90 P.3d 185 (Alaska Ct. App. 2004)
Michael Jeffries (defendant) was charged with criminal homicide when his drunk driving resulted in the death of the passenger in his car. During that instance of drunk driving, Jeffries’s only alleged careless act, beyond the fact of being impaired by intoxication, was a dangerous left turn that resulted in the fatal accident. Jeffries, however, had a long history of drunk-driving convictions, had refused to participate in court-ordered treatment programs, and his license had been revoked for the previous decade. Jeffries was convicted of second-degree murder. Jeffries appealed, alleging that his conduct of drunk driving with only one reckless turn was insufficient to establish that he had behaved with extreme recklessness as required to support a second-degree murder conviction, and that he should have only been found guilty of manslaughter.
Rule of Law
Holding and Reasoning (Mannheimer, J.)
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