In motor vehicle manslaughter cases where the vehicle was deliberately driven towards the deceased, the deliberate nature of the conduct is a feature that properly places the case among the more serious of its kind, even where the intention was only to frighten. Intoxication remains relevant to objective seriousness in such cases as it contributed to the offender getting behind the wheel and to the failure to stop. The question whether the need to resolve factual disputes on sentence by calling witnesses is relevant to the utilitarian value of a guilty plea was left open.
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