On January 13, 2021, at around 2 p.m., Jerry Dean Mittelstadt's truck crashed into a work site of the Iron County Road Commission in Iron County, Mich. The impact left a flagger who'd been directing traffic, 56-year-old Lawrence Leonarduzzi, pinned between a Road Commission vehicle and Mittelstadt's pickup.
Mittelstadt had turned on his cruise control and made no attempt to slow his vehicle before the crash, so he was traveling at around 50 miles per hour when he ran into Leonarduzzi. The victim suffered severe traumatic injuries and died at the scene.
There was no question Mittelstadt had been at the wheel when this accident occurred. But was he criminally responsible, or was there another explanation for the deadly crash?
Mittelstadt's case was covered on an episode of A&E’s Accused: Guilty or Innocent?
Charges Filed Against Mittelstadt
At the scene of the accident, Mittelstadt told police he must have fallen asleep at the wheel.
A 2020 report from the U.S. Department of Transportation and National Highway Traffic Safety Administration states that 2.2% of drivers involved in fatal crashes were drowsy, asleep, fatigued, ill or had blacked out at the wheel.
Yet there was no obvious explanation for Mittelstadt to have fallen asleep or lost consciousness. He said he hadn't been tired while driving.
Mittelstadt had two earlier convictions, from 2001 and 2006, for operating a vehicle while intoxicated in Jefferson County, Wisc. But after the 2021 crash, toxicology reports showed he was not under the influence of drugs or alcohol.
In April 2021, Iron County prosecutors charged Mittelstadt with one count of a moving violation causing death in a work or school bus zone and/or, alternatively, reckless driving causing death. In most cases, the maximum penalty for the charges would be 15 years in prison. However, Mittelstadt's two earlier convictions resulted in him receiving a habitual offender notice. This meant his sentence could be doubled if he was convicted.
Though he risked up to 30 years behind bars, Mittelstadt turned down a plea offer during a pretrial hearing on August 24, 2021.
The Sudden Emergency Doctrine
In Michigan, where Mittelstadt's deadly crash occurred, the sudden emergency doctrine applies "when a collision is shown to have occurred as the result of a sudden emergency not of the defendants' own making." This means a driver may not be liable if an unforeseeable emergency results in an accident.
It's only when drivers could not have predicted an emergency that they can avoid culpability. For example, fatigue can result in someone falling asleep at the wheel at an unknown time. However, the driver is responsible for making the choice to operate a vehicle when tired, so the sudden emergency doctrine would not take effect.
The same reasoning is used if a medical condition causes someone to black out while driving. If Mittelstadt had known he had a condition or illness that might make him lose consciousness, he would be responsible for any accident that resulted if he chose to drive. On the other hand, if Mittelstadt blacked out due to an unforeseen medical episode, it could fall under the sudden emergency doctrine and absolve him of criminal responsibility in Leonarduzzi's death.
Crashes that result from a driver's medical emergency are rare.
A National Motor Vehicle Crash Causation Survey conducted by the U.S. Department of Transportation examined crashes involving light passenger vehicles that occurred between 6 a.m. and 12 a.m. from July 3, 2005 to December 31, 2007. It found that only 1.3% of crashes were brought about by a driver's medical emergency.
Acting in Self-Defense: What It Means in the Eyes of the Law
The idea that people have a right to defend themselves harks back centuries and formed the basis of the American legal system.
The idea that people have a right to defend themselves harks back centuries and formed the basis of the American legal system.
Mittelstadt's Trial and Verdict
The trial People v Jerry Mittelstadt began on September 6, 2022, in Michigan's Iron County Courthouse. Prosecutors had opted not to pursue the reckless driving charge, so the jury only had to determine if Mittelstadt was guilty of a moving violation causing death in a work or school bus zone.
During the trial, defense attorney Karl Numinen displayed a photo showing that there was a straight stretch of road before the scene of the accident. As Mittelstadt had turned on his cruise control, his vehicle could have maintained its speed and remained on the road even if Mittelstadt lost consciousness. Numinen had a prosecution witness confirm that the absence of skid marks could indicate that Mittelstadt was not conscious when he hit Leonarduzzi.
Numinen also introduced medical experts who explained that Mittelstadt had been diagnosed with a paralyzed diaphragm. Though Mittelstadt had sought medical help following a December 2020 incident when he'd had trouble breathing at work, he had not been able to see the specialists who made this diagnosis until after the January 2021 accident, as the COVID-19 pandemic had increased wait times for medical care.
On the stand, experts explained that Mittelstadt's condition made his oxygen levels fluctuate, which could cause blackouts. After his diagnosis, Mittelstadt was told driving could be dangerous—but he did not know this before the crash.
The jury deliberated for 90 minutes on September 8, 2022, before finding Mittelstadt not guilty. Though relieved by the verdict, Mittelstadt did not forget Leonarduzzi and his grieving family. After the trial, he said, "At the end of the day, an accident still happened."
