CALCRIM No. 594

Code, § 192(c)(3))

The defendant is charged [in Count] with vehicular manslaughter

by causing a collision for financial gain [in violation of Penal Code

section 192(c)(3)].

To prove that the defendant is guilty of this crime, the People must

prove that:

1. While driving a vehicle, the defendant knowingly caused or

participated in a vehicular collision;

2. When the defendant acted, (he/she) knew that the purpose of the

vehicular collision was to make a false or fraudulent insurance

claim for financial gain;

3. When the defendant acted, (he/she) did so with intent to defraud;

AND

4. The collision caused the death of another person.

A person intends to defraud if he or she intends to deceive another

person in order to cause a loss of, or damage to, a legal, financial, or

property right.

[For the purpose of this instruction, a person includes (a governmental

agency/a corporation/a business/an association/the body politic).]

[An act causes death if the death is the direct, natural, and probable

consequence of the act and the death would not have happened without

the act. A natural and probable consequence is one that a reasonable

person would know is likely to happen if nothing unusual intervenes. In

deciding whether a consequence is natural and probable, consider all of

the circumstances established by the evidence.]

[There may be more than one cause of death. An act causes death only if

it is a substantial factor in causing the death. A substantialfactor is more

than a trivial or remote factor. However, it does not need to be the only

factor that causes the death.]

New January 2006; Revised April 2020