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State ex rel. Thomas v. Duncan

Court of Appeals of Arizona
165 P.3d 238 (2007)


William Reagan (defendant) claimed he was a victim of a road-rage incident. Reagan was driving a truck while his brother sat in the front passenger seat. Reagan claimed that the occupants of another vehicle made Reagan believe he was in danger of being injured or killed. According to Reagan, Reagan tried to drive away, but the other vehicle followed in pursuit. As the pursuit evolved into a chase, Reagan drove at high speeds to escape the other vehicle. Witnesses confirmed that both Reagan and another driver were speeding, but were unclear whether the vehicles were racing each other or whether one was chasing the other. Reagan ran a red light while going over 70 miles per hour in a 40 miles-per-hour zone. Reagan’s vehicle collided with the vehicle of a third party, killing the driver of that vehicle. Reagan was charged with manslaughter and sought to introduce evidence of the vehicle chase to negate the mens rea element of the offense. The state objected on the ground that the evidence impermissibly supported a justification defense that was inapplicable in Reagan’s case. The trial court ruled to allow Reagan to introduce the evidence for the purpose of negating mens rea. The state filed a special action, seeking to reverse the trial court’s order.

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Holding and Reasoning (Barker, J.)

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