State of Maine v. Arno A. Bittues, 208 A.3d 800

Around midnight on Feb 3, 2018, a trooper responded to a Wayne residence reporting moaning/yelling and found a minivan stuck in a snowbank in the driveway.
The trooper discovered Arno Bittues kneeling face down in the snow about 15–20 feet from the driveway; a single set of footprints ran from the driver’s side of the minivan to where Bittues was found.
Troopers detected a strong odor of alcohol, observed glassy/bloodshot eyes, and Bittues was unable to perform a field sobriety task; he had a .25 BAC on an intoxilyzer test.
Bittues admitted the van was his and that he was the only person who drove it, but would not confirm he had driven that night; he also gave an inaccurate location (thought he was in another town).
At bench trial Bittues conceded impairment but contested operation; the court found him guilty of OUI (Class D), imposed jail time (alternative program), a fine, and license suspension.
Bittues appealed arguing insufficient evidence that he operated the vehicle while intoxicated; the Supreme Judicial Court affirmed.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether evidence was sufficient to prove Bittues operated the vehicle while intoxicated	State: footprints, location of Bittues, his admissions, and intoxilyzer support operation	Bittues: photographs and second trooper’s testimony undermine connection between him and operation; alternative explanations exist	Court: Evidence viewed in State’s favor was sufficient; conviction affirmed

State v. Woodard, 68 A.3d 1250 (Me. 2013) (standard for reviewing sufficiency of evidence and viewing evidence in light most favorable to the State)
State v. Wilson, 127 A.3d 1234 (Me. 2015) (review of trial court factual findings for clear error in nonjury trials)
State v. Bowman, 611 A.2d 560 (Me. 1992) (alternative explanations need not be eliminated unless they raise a reasonable doubt)