Warden

I. Factual and Procedural Background

On March 19, 2000, Williams’ van veered off the road and onto a highway median, killing six teenagers who had been assigned to a road cleanup crew by Clark County Juvenile Services. Williams, who was twenty years old at the time, tes- tified that she had been up all night prior to the tragic inci- dent. She admitted that she had smoked marijuana about two hours before the accident and that she had used the drug “ec- stasy” the previous evening. Williams’ car drifted onto the median after she had apparently fallen asleep at the wheel. At the time of the accident, Williams had a pipe with marijuana residue and a plastic bag with marijuana in her car. Blood tests confirmed the presence of marijuana metabolites in her system. WILLIAMS v. WARDEN 12583 Williams was charged, inter alia, with six counts of violat- ing NRS 484.3795(1) for driving under the influence of a con- trolled substance and proximately causing the deaths of six persons. The six counts charged her under two subsections of NRS 484.3795(1). Under subsection (1)(d), in order to con- vict Williams, the jury needed to find her “under the influence of a controlled…