State of Minnesota v. Daniel Gebreamlak, A15-1915

Defendant Daniel Gebreamlak was charged with first‑degree driving while impaired; a related test‑refusal count was dismissed and the impaired‑driving charge was tried to a jury.
Officer Rushton observed speeding on snow‑covered roads, a temporary loss of vehicle control, lane changes without signaling, and a delayed stop after being signaled by police.
On contact the officer detected odor of alcohol, bloodshot/watery eyes, slurred speech, fumbling for his license, and divided‑attention/delayed motor skills.
Due to unsafe ground conditions, the officer performed only horizontal and vertical gaze nystagmus tests; Gebreamlak failed all segments of both tests and the officer observed pronounced nystagmus.
The jury found Gebreamlak guilty of driving under the influence; he appealed arguing insufficient evidence of impairment.

Issue	State's Argument	Gebreamlak's Argument	Held
Whether evidence was sufficient to convict for driving under the influence	The combination of driving behavior, odor, appearance/behavioral indicators, and failing both nystagmus tests proved impairment beyond a reasonable doubt	The evidence was circumstantial and could be explained innocently (road conditions, accent, natural causes of nystagmus/eye redness) so conviction lacked sufficient proof	Affirmed; evidence sufficient under both direct and heightened circumstantial‑evidence standards

State v. Silvernail, 831 N.W.2d 594 (Minn. 2013) (distinguishes review standards for direct vs. circumstantial evidence)
State v. Vang, 847 N.W.2d 248 (Minn. 2014) (standard for upholding jury verdict when evidence reasonably supports guilt)
State v. Al‑Naseer, 788 N.W.2d 469 (Minn. 2010) (framework for heightened scrutiny of circumstantial evidence convictions)
State v. Hawes, 801 N.W.2d 659 (Minn. 2011) (identifying circumstances proved consistent with a guilty verdict)
State v. Andersen, 784 N.W.2d 320 (Minn. 2010) (circumstances must be considered as a whole)
State v. Hughes, 749 N.W.2d 307 (Minn. 2008) (prosecution need not remove all doubt, only reasonable doubt)