State v. Henderson, 021418 MNSC, A16-0575
|Opinion Judge:||HUDSON, Justice.|
|Party Name:||State of Minnesota, Respondent, v. Tchad Tu Henderson, Appellant.|
|Attorney:||Lori Swanson, Attorney General, Saint Paul, Minnesota; and Anthony C. Palumbo, Anoka County Attorney, Kelsey R. Kelley, Assistant County Attorney, Anoka, Minnesota, for respondent. Douglas V. Hazelton, Andrew C. Wilson, Halberg Criminal Defense, Eden Prairie, Minnesota, for appellant. Cort C. Hol...|
|Case Date:||February 14, 2018|
|Court:||Supreme Court of Minnesota|
Office of Appellate Courts
Lori Swanson, Attorney General, Saint Paul, Minnesota; and Anthony C. Palumbo, Anoka County Attorney, Kelsey R. Kelley, Assistant County Attorney, Anoka, Minnesota, for respondent.
Douglas V. Hazelton, Andrew C. Wilson, Halberg Criminal Defense, Eden Prairie, Minnesota, for appellant.
Cort C. Holten, Jeffrey D. Bores, Gary K. Luloff, Chestnut Cambronne PA, Minneapolis, Minnesota, for amicus curiae Minnesota Police and Peace Officers Association Legal Defense Fund.
The term "operating" in Minn. Stat. § 609.2113, subd. 1 (2016), refers to any act that causes a motor vehicle to function or controls the functioning of a motor vehicle, including the act of a passenger grabbing the steering wheel of a moving vehicle.
The issue presented in this case is whether a passenger who grabs the steering wheel of a moving vehicle is "operating" the motor vehicle under the criminal-vehicular-operation statute, Minn. Stat. § 609.2113, subd. 1 (2016). The State charged appellant Tchad Tu Henderson with criminal vehicular operation after he grabbed the steering wheel of a moving vehicle, causing it to crash and inflict great bodily harm on the vehicle's three other occupants. The district court found that Henderson had operated the vehicle when he turned the steering wheel, and the court of appeals affirmed. Because the plain meaning of the term "operating" in the criminal-vehicular-operation statute unambiguously includes Henderson's conduct, we affirm.
Henderson, A.S., B.F., and B.H. had been at a bar together just minutes before the accident. B.H., who was sober, agreed to drive the group to their next destination. Henderson, who was under the influence of alcohol, sat in the front passenger seat of the vehicle. During the drive, Henderson and B.H. began arguing about how to get to their destination. At some point while the vehicle was in motion, Henderson yelled that B.H. should have made a turn, grabbed the steering wheel, and pulled it in his direction. B.H. had both hands on the steering wheel but could not resist because of the force that Henderson used. As a result of Henderson's actions, the vehicle swerved off the road, traveled part way up a support cable attached to a utility pole, and flipped upside down. It is undisputed that B.H., A.S., and B.F. all suffered great bodily harm.
The State charged Henderson with four counts of criminal vehicular operation resulting in great bodily harm under Minn. Stat. § 609.21 (2012): one count under subdivision 1(1) (grossly negligent), and three counts under subdivision 1(2)(i) (negligent while under the influence of alcohol).1 Henderson moved to dismiss the complaint based on a lack of probable cause that he was "operating" the motor vehicle. The district court denied the motion, and Henderson was subsequently convicted of all four counts.
Henderson appealed, challenging the denial of his motion to dismiss and arguing that the State had failed to present sufficient evidence that he had "operated" the motor vehicle. The court of appeals affirmed his convictions on counts two, three, and four, holding that "operation" includes the "manipulation of the steering wheel of a moving motor vehicle by a passenger." State v. Henderson, 890 N.W.2d 739, 744 (Minn.App. 2017).2 The court's conclusion was based on the "policy of giving impaired driving laws the broadest possible effect in favor of public safety, the plain meaning of the word 'operate, ' and the fact that the vehicle was not stationary when [Henderson] manipulated the steering wheel." Id. We granted review to determine whether a passenger who grabs the steering wheel of a moving vehicle is "operating" a motor vehicle under Minn. Stat. § 609.2113, subd. 1.
When a sufficiency-of-the-evidence claim turns on the meaning of the statute under which a defendant has been convicted, we are presented with a question of statutory interpretation that we review de novo. State v. Hayes, 826 N.W.2d 799, 803 (Minn. 2013). The goal of statutory interpretation is to ascertain and effectuate...
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