State v. Rivas

— Following his jury conviction for vehicular homicide by intoxication, Appellant Simon Rivas (Rivas) moved for arrest of judgment because the information did not include the nonstatutory element of a causal connection between intoxication and death. The trial judge denied the motion and Rivas appealed in Division One of the Court of Appeals. We accepted certification from that court and now hold that causation between intoxication and death is not an element of vehicular homicide.

Facts

On August 28, 1992, Rivas was the driver in a 1-car accident which left the passenger dead. Before the…