State Idaho v. Richard Allen Lee

In this case, the appellant, Richard A. Lee, challenges the district courts denial of his Rule 35 motion, in which Lee contended that the imposition of consecutive sentences for two counts of vehicular manslaughter arising out of a single accident was illegal. Lee raises the following issues on appeal: (1) whether his sentences were illegal because the Idaho vehicular manslaughter statute, I.C. § 18-4006(3), makes an act of driving which causes death in violation of the statute a single offense, regardless of the number of fatalities which result; (2) whether his sentences were illegal because the language of the vehicular manslaughter statute is ambiguous, and, under the doctrine of lenity, must be construed to bar more than one sentence for a single act of driving; and (3) whether his sentences were illegal because I.C. § 18-301 precludes multiple punishment for separate charges of vehicular manslaughter arising out of the same incident. For the reasons stated below, we affirm the decision of the district court.