351 S.W.3d 774
Mo. Ct. App.2011Background
- Hatfield was convicted in Cass County Circuit Court of driving while intoxicated (DWI) and driving while revoked; appeal challenges DWI conviction only.
- Scene: Deputy Shanks arrives at 814 Ward Road after a morning accident (approx. 11:00 a.m., Sept. 10, 2008) to find Hatfield next to a damaged car with rut marks and damaged fence.
- Hatfield admits he “lost it making the turn” and tells the deputy his license is revoked; deputy notes strong odor of alcohol, slurred speech, glassy eyes, and balance issues.
- Hatfield is arrested for DWI and revoked license; he refuses field sobriety tests and breath test after arrival at the sheriff’s office.
- The trial court previously found Hatfield a prior and persistent offender and imposed concurrent four-year sentences for DWI and revoked license; only the DWI conviction is challenged on appeal.
- The appellate court reverses Hatfield’s DWI conviction, while leaving intact the conviction for driving while revoked.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether there is sufficient evidence that Hatfield was intoxicated while driving. | Hatfield drove the car and was intoxicated at the time of the accident. | Intoxication was observed only at arrest, with no temporal link to driving. | DWI reversed for lack of temporal connection. |
| Whether the State proved a temporal link between operation of the vehicle and intoxication. | Evidence shows driving at the accident and intoxication at arrest; timing is inferable. | Circumstantial evidence supports intoxication while driving. | Insufficient temporal linkage; reversal of DWI conviction. |
| Whether Hatfield’s post-arrest refusals and conduct establish guilt despite evidentiary gaps. | Refusal to take tests shows consciousness of guilt. | Refusal after a time gap and possible access to alcohol undermine probative value. | Refusals do not, alone, prove intoxication during driving. |
Key Cases Cited
- State v. Davis, 217 S.W.3d 358 (Mo.App. W.D. 2007) (lacks temporal link between operation and intoxication; intoxication may occur later)
- State v. Byron, 222 S.W.3d 338 (Mo.App. W.D. 2007) (no evidence of contemporaneous intoxication; reversal when time interval uncertain)
- State v. Wilson, 273 S.W.3d 80 (Mo.App. W.D. 2010) (requires temporal connection; not enough to show intoxication at arrest only)
- State v. Ollison, 236 S.W.3d 66 (Mo.App. W.D. 2007) (insufficient evidence of interval between operation and arrest)
- State v. Varnell, 316 S.W.3d 510 (Mo.App. W.D. 2010) (detailed facts can sustain DWI if timely; distinguishes cases with weak temporal link)
- State v. Liebhart, 707 S.W.2d 427 (Mo.App. W.D. 1986) (reversal where no evidence of time of accident or alcohol access)
- State v. Grim, 854 S.W.2d 403 (Mo. banc 1993) (reaffirms need to prove guilt beyond reasonable doubt with temporal connection)