Court Finds Sufficient Evidence to Convict Where Inebriated Defendant Drove on Public Highways to Get to Private Road
In a criminal law matter, the Appellate Court of Connecticut considered whether the State provided insufficient evidence to support the defendant’s conviction for operating a motor vehicle while under the influence (OMVUI) in violation of Connecticut General Statutes § 14-227a.
This case arose from an incident that occurred on February 1, 2005. The defendant spent the late afternoon and evening with friends at various restaurants in Brookfield and Danbury, where she consumed alcoholic beverages. The manager at the third restaurant asked the defendant to leave because “she was being loud and vulgar and was annoying other patrons.” Around 7:30pm, the defendant drove her car to a nearby dead-end street and parked it in the middle of the road, obstructing traffic in both directions.
A resident called police because the car was still there an hour and fifteen minutes later. When the officer arrived, he saw that the motor was running with the taillights illuminated and radio on. The defendant was sound asleep in the driver’s seat, but with significant effort, the officer was able to wake her up. The defendant had bloodshot eyes, smelled of alcohol, and was quite disoriented. She quickly became uncooperative and would not obey the officer’s orders. The officer was unable to administer the field sobriety tests because of the defendant’s “combative and aggressive behavior.” At the police station, the defendant refused to submit to the breathalyzer test.
The defendant was charged with OMVUI, among other crimes. At trial, defense counsel argued that the defendant was only seen operating her car on the dead-end street, which was not a public highway under § 14-227a. The State countered that she traveled on two public highways to get to the dead-end street, thus satisfying this element. The defendant was convicted on all counts and appealed, arguing, in part, that there was insufficient evidence to prove, beyond a reasonable doubt, that she committed OMVUI.
Determining an OMVUI Conviction
To convict a defendant of OMVUI, the State must prove, beyond a reasonable doubt, that he/she operated a motor vehicle on a public highway while under the influence of alcohol or drugs. When a reviewing court adjudicates a sufficiency of the evidence claim, it construes the evidence so as to favor sustaining the verdict. It then determines whether, based on the facts and attendant inferences, a reasonable jury would have found that “the cumulative effect of the evidence established guilt beyond a reasonable doubt.” The jury is the “arbiter of credibility,” and it is not expected to leave common sense and knowledge “at the courtroom door.”
In this case, the Appellate Court found that a jury could reasonably conclude that the defendant was under the influence of the numerous alcoholic drinks she consumed before driving on various public highways to reach the dead-end street. The State met its burden of providing sufficient evidence satisfying the three elements of OMVUI, and after addressing an additional matter on appeal, the Appellate Court affirmed the judgment.
When faced with a charge of operating a motor vehicle while intoxicated (a.k.a. driving under the influence) or license suspension, an individual is best served by consulting with an experienced criminal law practitioner. Should you have any questions regarding criminal defense, please do not hesitate to contact Attorney Joseph C. Maya in the firm’s Westport office in Fairfield County at 203-221-3100 or at JMaya@Mayalaw.com.