Commonwealth v. Tarrach
42 A.3d 342
| Pa. Super. Ct. | 2012Background
- April 30, 2009, a two-vehicle crash in South Heidelberg Township, Berks County, leads to Tarrach being the driver of the striking vehicle.
- Pappas, the other driver, testified Tarrach approached after the crash with an unsteady gait; his vehicle was struck, causing damage.
- Officer Vargo observed Tarrach as unsteady, with glassy eyes and slurred speech; Tarrach admitted prescription drug use and refused medical treatment.
- Tarrach failed standard field sobriety tests; she was arrested for suspicion of driving under the influence and transported for blood testing.
- Toxicology showed Alprazolam, Amphetamine, Citalopram, Hydroxyzine, Oxycodone, and Topiramate; Dr. Labay opined impairment due to the drug combination.
- Tarrach was convicted at a bench trial of DUI under 75 Pa.C.S.A. § 3802(d)(2) and following too closely under § 3310(a); she appeals on sufficiency of evidence.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of DUI evidence | Tarrach contends no impairment proof beyond drug presence. | Commonwealth argues psychiatric/physical evidence and testimony show impairment. | Sufficient evidence supported impairment. |
| Sufficiency of following too closely | Tarrach was not following closely if Pappas was stopping or stationary. | Commonwealth contends Tarrach followed too closely, causing collision. | Sufficient evidence supported following too closely. |
Key Cases Cited
- Commonwealth v. Mobley, 14 A.3d 887 (Pa.Super.2011) (sufficiency standard for criminal evidence; appellate deference to verdict)
- Commonwealth v. Mollett, 5 A.3d 291 (Pa.Super.2010) (sufficiency review framework for criminal convictions)
- Commonwealth v. Williamson, 962 A.2d 1200 (Pa.Super.2008) (drug presence plus impairment evidence suffices for DUI; no expert necessary)
- Commonwealth v. Griffith, 32 A.3d 1231 (Pa.2011) (drugs in system plus observations and field tests can prove impairment)
- Commonwealth v. Bybel, 779 A.2d 523 (Pa.Super.2001) (tailing distance and accident contexts informing § 3310(a) analysis)
- Commonwealth v. Phinn, 761 A.2d 176 (Pa.Super.2000) (purpose of § 3310(a) to prevent accidents; reasonable distance analysis)