Jacob Thomas Gaulden v. State of Florida, 195 So. 3d 1123

Background

Jacob Gaulden was charged under Fla. Stat. § 316.027(1)(b) for leaving the scene of a crash that resulted in a death after his passenger exited a moving truck and died from injuries on the roadway.
At trial the jury convicted Gaulden; the First District reversed a trial-court dismissal and affirmed the conviction on remand, holding a vehicle may be “involved in a crash” when a passenger separates from a moving vehicle and collides with the road.
The First District certified a question of great public importance: whether a vehicle is “involved in a crash” if a passenger collides with the roadway after separating from the moving vehicle when the vehicle itself made no physical contact with any person, object, or other vehicle.
The Florida Supreme Court reviewed de novo, applying rules of statutory construction and strict construction for criminal statutes, and noted the Legislature replaced the word “accident” with the narrower term “crash.”
The Court concluded the phrase “vehicle involved in a crash” requires the vehicle to collide with another vehicle, person, or object; under the undisputed facts no vehicle collided with anything, so the statute did not apply.
The Supreme Court quashed the district court decision, answered the certified question in the negative, and remanded for application of its ruling.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a vehicle is “involved in a crash” when a passenger separates from a moving vehicle and collides with the roadway although the vehicle made no physical contact with anything	Gaulden: statute requires actual vehicle collision to trigger duties; defense argued strict construction favors accused	State: “involved” is broad; vehicle need not physically contact another object — causation or effect suffices	No — the Court held “involved in a crash” requires the vehicle itself to collide with a person, vehicle, or object
Whether the term crash should be read broadly (e.g., any harmful event)	Gaulden: legislative change from “accident” to “crash” indicates narrowing to collisions	State: prior case law and dictionary definitions support broader meaning covering causal involvement	Held that “crash” implies a collision; statutory text and rule of lenity require narrow construction
Whether strict construction and the rule of lenity apply	Gaulden: criminal statute must be strictly construed in favor of accused	State: public-protection purpose supports expansive reading	Held: strict construction and lenity control; ambiguous criminal statutes construed for the accused
Whether knowledge instruction (knew or should have known) was erroneous	Gaulden argued trial court should have required actual knowledge of a crash	State relied on precedent equating knowledge of injury with duties triggered	Held: Court rejected Gaulden’s knowledge argument earlier cited precedent (Dumas) and did not disturb the jury instruction ruling in this opinion; primary decision focused on definition of “involved in a crash.”

Key Cases Cited

Gaulden v. State, 132 So.3d 916 (Fla. 1st DCA 2014) (district-court decision under review holding passenger impact with roadway can make vehicle “involved in a crash”)
State v. Gaulden, 134 So.3d 981 (Fla. 1st DCA 2012) (earlier panel opinion reversing dismissal and defining “involved” broadly)
State v. Dumas, 700 So.2d 1223 (Fla. 1997) (knowledge element for duty is same whether injury or death)
State, Dep’t of Highway Safety v. Williams, 937 So.2d 815 (Fla. 1st DCA 2006) (dictionary usage of “crash” and rejection of adding unstated elements to statute)
State v. Elder, 975 So.2d 481 (Fla. 2d DCA 2007) (driver held “involved” when her driving caused another vehicle to crash)
Armstrong v. State, 848 N.E.2d 1088 (Ind. 2006) (interpreting statutory term “accident” broadly to include passenger ejection from moving vehicle)
McBoyle v. United States, 283 U.S. 25 (1931) (rule that criminal statutes should not be extended beyond their plain meaning)