People v. Beck

Defendant was convicted, after stipulated bench trial, of aggravated DUI. Plain language of statute required only that Defendant’s conduct in DUI was a proximate cause of other driver’s injuries, not sole or immediate cause. That other driver’s own conduct contributed to injuries would not relieve Defendant of criminal liability. Thus, court’s decision to preclude evidence that other driver was not wearing her seat belt did not deny Defendant the ability to present a defense. Retrograde extrapolation evidence as a method of estimating a person’s BAC has general acceptance in its relevant scientific community. Court did not abuse its discretion in finding State’s expert qualified to render opinions on topic of retrograde extrapolation. (STEIGMANN and DeARMOND, concurring.)