Com. v. Caraballo, A.
2024 Pa. Super. 234
| Pa. Super. Ct. | 2024Background
- Anthony John Caraballo was stopped by a state trooper in Lancaster County, PA, after he was observed driving erratically (crossing lane lines) early in the morning.
- The trooper noted Caraballo’s slurred speech, disheveled appearance, lethargic movement, poor performance on field sobriety tests, and absence of alcohol odor during the stop.
- Caraballo admitted taking Vivitrol, claimed he was tired from work, and refused a blood draw after being advised of his rights, opting for civil penalties.
- The Commonwealth charged Caraballo with DUI (controlled substances) and related traffic offenses; the jury convicted him of DUI, and the court convicted him of other offenses.
- On appeal, Caraballo argued the evidence was insufficient to establish drug-induced impairment and objected to the jury instruction that expert testimony was not required to convict for DUI under Section 3802(d)(2).
Issues
| Issue | Caraballo’s Argument | Commonwealth’s Argument | Held |
|---|---|---|---|
| Sufficiency of evidence for DUI conviction under 75 Pa.C.S.A. § 3802(d)(2) | Evidence was insufficient to prove impairment was drug-induced, and trooper was not qualified as an expert | Trooper’s lay opinion, Caraballo’s behavior, admission, video, and refusal sufficed for jury to find impairment by drugs | Evidence was sufficient; conviction affirmed |
| Appropriateness of jury instruction stating expert testimony not required | Claimed jury was misled; argued expert needed to tie impairment to drug | Instruction was proper given trial evidence; expert not required if lay testimony and other evidence supports impairment | Jury instruction upheld; no abuse of discretion |
Key Cases Cited
- Commonwealth v. Griffith, 32 A.3d 1231 (Pa. 2011) (proof of drug-related DUI impairment does not require a specific quantity or expert testimony; case-by-case analysis)
- Commonwealth v. Spence, 290 A.3d 301 (Pa. Super. 2023) (standard for sufficiency of evidence in criminal cases)
- Commonwealth v. DiPanfilo, 993 A.2d 1262 (Pa. Super. 2010) (refusal of chemical testing can evidence consciousness of guilt)
- Commonwealth v. Gause, 164 A.3d 532 (Pa. Super. 2017) (en banc) (factual inference and credibility standards for sufficiency review)