## Facts

- Raymond J. Iten drove a tractor-trailer eastbound on Highway 55 toward a signalized intersection with South Shore Drive.
- He observed the traffic signal change from green to yellow and then to red while still approaching the intersection.
- Believing he could not stop safely, Iten chose not to stop at the red light and sounded his horn to warn traffic.
- As a car driven by Marna Quarnstrom entered from the south, Iten downshifted and moved left in an attempt to avoid impact.
- The truck struck Quarnstrom’s vehicle; she was ejected and then run over by the truck’s rear wheels, causing instantaneous death.
- Post-collision mechanical evidence showed the truck’s brakes operated at roughly 50% effectiveness due to rust and oil deposits.
- Evidence indicated Iten had adequate time and distance to stop safely despite the brake condition.
- Iten did not perform a required pre-trip brake inspection, explaining he was in a hurry.
- A grand jury indicted Iten for criminal vehicular operation resulting in death under Minn. Stat. § 609.21, subd. 1(1) (1984), and a jury convicted him.

## Issues

1. Whether the indictment should have been dismissed because alleged inconsistencies in grand-jury testimony meant the grand jury lacked sufficient competent evidence.
2. Whether the trial evidence was sufficient to prove criminal vehicular operation resulting in death.
3. Whether the trial court erred by excluding evidence that the victim was not wearing a seatbelt, and whether exclusion was prejudicial.
4. Whether the jury instructions on causation and negligence, including the treatment of “proximate cause,” were erroneous or misleading.

## Decision

- The court affirmed the conviction.
- The indictment stood because minor discrepancies in eyewitness accounts did not negate probable cause where the core narrative was supported by substantial testimony.
- The evidence was sufficient for a reasonable jury to find that Iten’s conduct satisfied the statutory standard and caused the death.
- Excluding seatbelt nonuse evidence was not error and, in any event, did not prejudice the defense.
- The jury instructions, considered as a whole, accurately stated the governing causation standard and did not warrant reversal.

## Legal Principles

- An indictment is not invalidated by minor inconsistencies in witness testimony if the evidence, taken as a whole, establishes probable cause.
- In reviewing sufficiency, the evidence is viewed in the light most favorable to the verdict, with deference to the jury’s credibility determinations.
- A driver’s failure to comply with vehicle-safety inspection requirements and the decision to proceed despite conditions affecting safe stopping can support criminal vehicular operation liability when the conduct results in death.
- A victim’s contributory negligence is not a defense in a criminal prosecution; evidence offered solely to attribute fault to the victim may be excluded as irrelevant and potentially confusing.
- Criminal causation instructions need not adopt civil “proximate cause” terminology if the instructions clearly require proof that the defendant’s unlawful conduct resulted in the prohibited harm.

## Conclusion

The court affirmed Iten’s conviction for criminal vehicular operation resulting in death, holding that minor testimonial inconsistencies did not undermine the indictment, the trial evidence supported the verdict, seatbelt nonuse was irrelevant to criminal culpability, and the causation instructions fairly stated the law without importing civil proximate-cause concepts.


State v. Iten, 401 N.W.2d 127 (Minn. Ct. App. 1987)