Beattie v. State, 88 A.3d 906

Early morning collision on I-70: appellant Bruce Beattie (commercial 70-ft tractor-trailer) crossed three lanes from the right shoulder toward an emergency median crossover to reverse direction; impact killed driver Michael Neimus.
Appellant initially told police he was on the shoulder looking at a map and was rear-ended; later revised his statement admitting he pulled onto the roadway and began a U-turn and conceded the crash could have been avoided.
Crash reconstruction and vehicle "black box" data showed Neimus was traveling ~62 mph, had ~1.5 seconds to respond once the truck began pulling out, and that the truck accelerated to ~10.5 mph; investigators concluded the truck’s maneuver left insufficient time/distance to avoid the collision.
Neimus’s BAC was .14 and marijuana was recovered, but the trial court found no negligence by the victim in his handling of the vehicle sufficient to absolve appellant.
Appellant was convicted of criminally negligent manslaughter under Md. Code (2011 Supp.) Crim. Law § 2-210 and related traffic offenses; sentenced to one year; appellant appealed raising (1) vagueness of § 2-210 and (2) insufficiency of the evidence.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether CL § 2-210 is unconstitutionally vague	§ 2-210’s term “criminal negligence” is ambiguous and fails to give fair notice or guidance; interchangeable historic use with “gross negligence” creates uncertainty	§ 2-210 defines criminal negligence clearly (failure to perceive substantial unjustifiable risk + gross deviation) and aligns with Maryland/Model Penal Code guidance; not vague	Statute is not unconstitutionally vague; provides adequate notice and enforceable standard
Whether evidence was sufficient to convict under § 2-210	Ambiguity in statute prevents a lawful conviction; facts do not establish the intermediate mental state distinct from gross negligence	Evidence (maneuver, time/distance, black box data, admissions) showed a substantial/unjustifiable risk and a gross deviation in failing to perceive it	Viewing evidence in prosecution’s favor, a rational factfinder could find all elements beyond a reasonable doubt; conviction affirmed

Walker v. State, 432 Md. 587 (discussing presumption of constitutionality and vagueness analysis)
Galloway v. State, 365 Md. 599 (vagueness doctrine; role of enforcement discretion)
Livingston v. State, 192 Md. App. 553 (vagueness burden and standards)
Albrecht v. State, 336 Md. 475 (overview of negligence standards in manslaughter context)
Dishman v. State, 352 Md. 279 (gross negligence requires consciousness of risk)
DeHoge v. State, 190 Md. App. 532 (definition of wanton or reckless disregard for human life)
State v. Randol, 597 P.2d 672 (Kan. 1979) (upholding intermediate negligence standard against vagueness challenge)