A federal judge in San Diego has dismissed a vehicular manslaughter case against a local Border Patrol agent, ruling that as a federal agent he is immune from state prosecution because he was acting within the scope of his authority when he was involved in a fatal crash with a motorcyclist last year.
County prosecutors charged Agent Dustin Sato-Smith in state court with a misdemeanor count of vehicular manslaughter without gross negligence in the collision death of Jacumba Hot Springs resident Ellis James Woodall near Potrero. But Sato-Smith successfully petitioned to move his case to federal court, where he claimed absolute immunity from state court criminal proceedings.
Sato-Smith argued that he was doing his job as a federal agent at the time of the February 2023 crash and thus was protected by the Supremacy Clause of the U.S. Constitution, a principle establishing that federal laws take precedence over conflicting state laws.
U.S. District Judge James Simmons agreed with Sato-Smith, ruling the agent was performing his necessary job duties and responding to an emergency. In a written ruling issued Monday, Simmons granted Sato-Smith’s motion to dismiss the case and acquitted him of the state manslaughter charge.
“Defendant argues that his U-turn which led to the collision in this case was necessary and proper, in the reasonable performance of his duties and were related to an exigency to arrive at the location of the call for service,” Simmons wrote. “The Court agrees.”
A spokesperson for the San Diego County District Attorney’s Office said the office “accept(s) the court’s decision.”
The fatal crash occurred around 8 p.m. on Feb. 19, 2023, on Campo Road near the U.S.-Mexico border. Sato-Smith was driving a Border Patrol transport van on the rural, two-lane highway when he heard a radio call about possible undocumented migrants preparing to cross the border.
Sato-Smith decided to respond to the call, which required he turn the van around and drive in the opposite direction. According to his attorney, the agent waited to make a U-turn until he reached an area he thought would be safe. But as Sato-Smith started his U-turn, Woodall was approaching from behind on his Kawasaki motorcycle and beginning a legal passing maneuver in the opposite lane.
Woodall, 37, slammed into the driver’s side of the Border Patrol van as it turned into his path, ending up pinned under its right rear tire. He died at the scene. The involvement of a Border Patrol agent and other details of the crash were first reported by the Union-Tribune in July.
A California Highway Patrol investigation later determined Sato-Smith, who’d been airlifted to a hospital for his injuries, had committed an infraction by “making his U-turn … directly into the path” of the motorcycle. The CHP concluded the agent was at fault for the deadly collision and should be charged. On Valentine’s Day this year, nearly a year after the fatal collision, the county District Attorney’s Office charged Sato-Smith with the misdemeanor manslaughter count.
It’s rare for federal government employees to be accused of violating state laws because the Supremacy Clause largely protects them from state court prosecutions. Congress has also passed regulations giving the federal government and its employees the legal right to move any criminal or civil case filed against them in state court to federal court. That’s what Sato-Smith did.
“The traffic collision was an unfortunate situation with a tragic outcome,” defense attorney Rick Pinckard told the Union-Tribune. “Nonetheless, the legal precedent relied upon by the court is necessary to maintain the proper balance of power between the federal government and the states, as it pertains to federal officers performing their duties within the jurisdictional boundaries of a state.”
The District Attorney’s Office had argued that Sato-Smith should not be able to move the case to federal court because he was not responding to an emergency when the crash occurred. The county prosecutors argued that if he had been, Sato-Smith would have activated his emergency lights and would not have slowed down before making the U-turn.
The judge rejected those arguments, reasoning the agent had to slow down to make a safe turn and did not activate his lights so as not to alert potential migrant smugglers that he was approaching.
