State of Minnesota, Respondent, vs. Henry Lee Brown, Appellant

Summary

The court held that the criminal vehicular homicide statute for leaving the scene does not require the State to prove that the defendant was operating the vehicle at the precise time of the collision. An act of operating the vehicle before the collision is sufficient if that operation proximately caused the death, and Brown admitted that he operated the vehicle before losing consciousness, left the scene, and failed to notify police. The court therefore affirmed the denial of Brown's motion to withdraw his guilty plea and did not reach whether operation at the time of the collision had to be volitional.