Gaulden v. State
Annotate this CasePetitioner was driving a truck with when the passenger opened the passenger door. The passenger suddenly left the moving vehicle and was later found dead on the ground adjacent to the roadway. Petitioner was convicted of leaving the scene of a crash that resulted in death in violation of Florida’s hit-and-run statute. The First District Court of Appeal affirmed, concluding that a driver’s vehicle may be “involved in a crash” pursuant to the statute when a passenger separates from a moving vehicle and lands on the roadway or adjacent area. The Supreme Court quashed the decision below, holding (1) the statutory phrase “any vehicle involved in a crash” means that a vehicle must collide with another vehicle, person, or object; and (2) under the facts of this case, no vehicle was involved in a collision within the meaning of the statute, and therefore, Petitioner’s conviction cannot be upheld.
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