People v. Watson

People v. Watson was a 1981 California Supreme Court case that established that DUI drivers can be charged with murder.

People v. Watson is an important California Supreme Court case which determined that DUI drivers can, under certain circumstances, be charged with second-degree murder if they caused an accident that took a life.

The case started with an accident in the early morning of January 3, 1979. Robert Watson had been drinking beer at a bar and then left to drive home in his car. On the way, he narrowly avoided one accident when he went through a red light, then left the scene at high speed. At the next intersection he slammed into the back of a small car. When Watson struck the other car, two people were thrown from the vehicle. Two people died.

Watson’s speed at the time of the collision was estimated between 55 mph and 70 mph, in an area where the speed limit was 35 mph. His blood alcohol content (BAC) a half hour after the accident was 0.23%, nearly three times the legal limit. Given these factors and his extraordinarily reckless driving, the prosecutors in the case decided to charge him with murder.

At the time, murder was not a normal charge for a DUI death. DUI deaths are normally prosecuted as vehicular manslaughter, which carries less severe penalties. The difference between manslaughter and murder, in layman’s terms, is that murder is generally intentional whereas manslaughter is accidentally killing someone while doing something you should not have done.

Because the murder charges were unheard of, Watson’s defense team requested that the judge dismiss them. Eventually, this matter went all the way to the state Supreme Court. In 1981, the Court heard the case and agreed that Watson could be charged with murder.

As a result of this decision, other DUI defendants in California can also be charged with murder under some circumstances.

Why is an accidental DUI death “murder”?

Murder does not simply mean taking a life. In the eyes of the law, it means you did something that resulted in a person dying, and that you did it in a state of mind known as “malice aforethought.” Malice aforethought means that you knew in advance that you could hurt or kill someone, and you didn’t care—you didn’t let that stop you from doing it.

The malice in a DUI murder case is known as implied malice. Implied malice doesn’t mean you set out to explicitly hurt someone. It means that your actions implied a wanton and conscious disregard for human life. In other words, you knew you could kill someone and you did it anyway.

Invoking implied malice for a DUI death is extremely controversial. However, because of the California Supreme Court’s decision in People v. Watson, prosecutors can and sometimes do choose to do it. To prove their case, however, they have to prove not only that your actions implied malice, but also that you knew the risk that DUI driving poses to other people. This is why first-time DUI offenders are asked to sign a Watson advisement.

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