The Michigan Supreme Court recently ruled that evidence of a decedent's blood alcohol concentration (BAC) can be admitted in a case involving a moving violation causing death. This decision impacts the case of Michael M. Morgan, who was charged after a collision resulted in the death of motorcyclist Donald D. Arnold. The ruling clarifies how evidence of intoxication can be relevant in determining causation in such cases.
The court's decision, filed on June 24, 2026, comes after a series of lower court rulings that initially excluded the BAC evidence. The court's ruling is significant as it sets a precedent for future cases involving similar circumstances, potentially affecting how evidence is presented in trials involving traffic violations and fatalities.
Background
The case began when Michael M. Morgan was charged in the 53rd District Court with a moving violation causing death under Michigan law, specifically MCL 257.601d(1). This charge stemmed from a collision between Morgan's car and a motorcycle driven by Donald D. Arnold, who died from his injuries shortly after the accident.
Eyewitnesses reported that Arnold accelerated quickly after a traffic light turned green, striking the side of Morgan's vehicle as he attempted a U-turn. Morgan sought to introduce evidence suggesting that Arnold may have been speeding—possibly exceeding the posted limit by 20 miles per hour—and that his BAC at the time of the collision might have been between 0.071 and 0.081 grams per deciliter. The district court allowed the speed evidence but excluded the BAC evidence, leading to an appeal.
After the district court's decision, Morgan's application for leave to appeal was denied by the Livingston Circuit Court. However, the Court of Appeals later affirmed the district court's ruling, citing a precedent that required a preliminary showing of gross negligence before BAC evidence could be considered admissible. Morgan then appealed to the Michigan Supreme Court.
The Ruling
The Michigan Supreme Court ruled in favor of Morgan, stating that the district court had abused its discretion by excluding the BAC evidence. Justice Noah P. Hood, writing for the court, emphasized that the BAC evidence was relevant under Michigan Rule of Evidence (MRE) 401 because it could help establish proximate causation in light of other admissible conduct.
The court ruled, "The district court abused its discretion by excluding the evidence of the decedent’s possible intoxication... the risk of unfair prejudice was low compared to the evidence’s probative value in determining whether the decedent’s intoxication, speed, and acceleration constituted gross negligence or a superseding cause of the collision."
The court found that the lower courts had misapplied the principles from the precedent case, People v. Feezel, which established that evidence of a victim's BAC must have any tendency to make gross negligence on the part of the victim more or less probable. The court noted that the BAC evidence was relevant because it could inform the jury about the decedent's actions leading up to the collision.
The court's ruling reversed the Court of Appeals' judgment, vacated the district court's order, and remanded the case back to the district court for further proceedings. This decision allows for a more comprehensive examination of the evidence surrounding the collision.
Impact
This ruling has significant implications for future cases involving moving violations and fatalities. It clarifies that evidence of a victim's intoxication can be relevant in determining proximate cause, particularly when combined with other factors, such as speeding. The decision sets a precedent that may influence how similar cases are handled in Michigan, potentially allowing for a broader interpretation of admissible evidence in traffic-related fatalities.
By allowing the BAC evidence to be presented, the court has opened the door for juries to consider all relevant factors when determining causation and negligence. This could lead to more nuanced outcomes in cases where the actions of both the defendant and the victim are under scrutiny.
What's Next
The case will return to the district court for further proceedings, where the admissibility of the BAC evidence will now play a critical role in the trial. It is unclear whether Morgan will appeal any future decisions made by the district court, but the ruling has already established a significant legal precedent in Michigan.