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Name: People v. Vela
Case #: C066404
Court: CA Court of Appeal
District 3 DCA
Opinion Date: 04/30/2012

Vehicle Code section 20001, subdivision (c), provides a sentence enhancement for gross vehicular manslaughter when an intoxicated driver flees the scene of the crime and there is substantial evidence to support the finding when the driver leaves her car and identification before fleeing. While driving under the influence of alcohol, appellant collided with a motorcycle and her vehicle crashed through a sound wall. She got out of the car and walked briskly away from the scene. When an officer caught up with her, she stated that she had left her driver’s license in her car at the scene. Relying on CALCRIM No. 2160, appellant argued that there was insufficient evidence to support the Vehicle Code section 20001, subdivision (c), enhancement because she stopped after hitting the wall. The Court of Appeal concluded that CALCRIM No. 2160 is legally inaccurate and that the proscribed conduct under subdivision (c) is “fleeing the scene of a crime.” The purpose of Vehicle Code section 20001, subdivision (c), is to preserve evidence of a DUI. Evidence would have potentially been lost if appellant had escaped detection and remained in hiding until her level of intoxication could no longer be reliably determined. There was substantial evidence to support the enhancement based on appellant’s efforts to leave the scene.