People of Michigan v. Karlton Terry Lewis, 329383

On Jan. 25, 2015 in Detroit, Lewis (defendant) was driving westbound at ~75–78 mph in a 35 mph zone on wet pavement and was intoxicated (BAC 0.155).
Janitta Simpson was driving eastbound and intoxicated (BAC 0.147); she attempted a left turn near Greenfield/McNichols.
Lewis ran a yellow light and struck the passenger side of Simpson’s vehicle; Yvette Brown (front-seat passenger) died.
Both drivers were charged with OUIL causing death (MCL 257.625(4)(a)); Lewis was convicted after a bench trial, Simpson was acquitted of that charge and convicted of OUIL.
The critical legal dispute was causation: whether Lewis’s conduct was a proximate cause of Brown’s death or whether Simpson’s left turn constituted a superseding intervening cause (gross negligence) that severed the causal chain.
The trial court credited an accident-reconstruction expert who testified Simpson was braking and turning in a normal manner and could not accurately judge Lewis’s closing speed at night; the court found Lewis’s speeding and driving through a yellow light proximately caused the death and Simpson’s conduct was ordinary negligence only.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was Lewis’s operation of the vehicle a proximate cause of Brown’s death?	Lewis’s speeding and driving through a yellow light caused the crash and death.	Lewis contended his conduct was not the proximate cause because Simpson’s turn was a superseding cause.	Court held Lewis’s conduct was a proximate cause.
Did Simpson’s turn constitute a superseding intervening cause that broke the causal chain?	Simpson’s left turn was foreseeable ordinary negligence and did not supersede Lewis’s culpable conduct.	Lewis argued Simpson’s turning/swerve was gross negligence unforeseeable, severing liability.	Court held Simpson’s conduct was ordinary negligence, not gross negligence, so it did not supersede.
Was the verdict against the great weight of the evidence?	Prosecution: the evidence supported the trial court’s factual findings and credibility determinations.	Lewis: verdict inconsistent with evidence because Simpson had the right to turn and her conduct was the real cause.	Court found no clear error; verdict not against great weight of evidence.
Was the trial court’s factual finding (bench trial) clearly erroneous?	Prosecution relied on expert testimony and objective evidence to support findings.	Lewis argued the court erred in assessing foreseeability and causation.	Court held the trial court’s findings were not clearly erroneous.

People v Feezel, 486 Mich 184 (2010) (ordinary negligence by victim or third party is foreseeable and typically will not break causal chain)
People v Clark, 171 Mich App 656 (1988) (proximate cause and intervening cause are factual questions for trier of fact)
Lanzo Constr Co v, 272 Mich App 470 (2007) (bench-trial factual findings reviewed for clear error)
People v Johnson, 466 Mich 491 (2002) (definition of clear error standard)
People v Williams, 268 Mich App 416 (2005) (appellate court defers to trier of fact on credibility and weight of evidence)
People v McCray, 245 Mich App 631 (2001) (standard for verdict against the great weight of the evidence)
People v Schaefer, 473 Mich 418 (2005) (elements of OUIL causing death and analysis of factual vs. proximate causation; foreseeability and superseding cause framework)
People v Lardie, 452 Mich 231 (1996) (mens rea/gross negligence inference where defendant knowingly consumed intoxicant and voluntarily drove)