Motor Vehicle Administration v. Carpenter, 36 A.3d 439

Carpenter was stopped after a two-vehicle collision in Elkton; the other vehicle was registered to Carpenter.
Witnesses described Carpenter’s truck as traveling fast and striking the other car; Carpenter admitted traveling from Delaware to Elkton after drinking two beers.
Officer Pirritano observed signs of intoxication (strong odor, red watery eyes, slurred speech) and Carpenter failed standard field sobriety tests, then refused a breath test.
Carpenter was read the DR-15 Rights Form; he refused to take the chemical breath test, resulting in suspension proceedings under § 16-205.1.
The ALJ found there were reasonable grounds to detain Carpenter for driving under the influence based on the totality of circumstances, including the scene and witness statements.
The Cecil County Circuit Court reversed, holding there was no sufficient evidence Carpenter was the driver; MVA appealed for affirmance of the ALJ’s reasonable grounds finding.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether officer had reasonable grounds to detain Carpenter	MVA: totality of circumstances showed driving inferral from scene and witness statements.	Carpenter: no witness testified he was the driver; inference not reasonably supported.	Officer had reasonable grounds; denial of reversal affirmed

Maryland Aviation Administration v. Noland, 386 Md. 556 (2005) (narrow standard of review for agency adjudications; substantial evidence and no erroneous law)
MVA v. Shea, 415 Md. 1 (2010) (deference to agency findings; substantial evidence review)
Crosby v. State, 408 Md. 490 (2009) (reasonable articulable suspicion standard; deference to officer inferences)
Robinson v. State, 315 Md. 309 (1989) (common sense inferences from established facts)
Evans v. State, 28 Md.App. 640 (1975) (illustrates inference from circumstantial evidence)
Attorney Grievance v. Walter, 407 Md. 670 (2009) (circumstantial evidence and inference acknowledged in claims)