State v. Soucy
2012 ME 16
| Me. | 2012Background
- Soucy appeals a conviction for operating under the influence with one prior OUI within 10 years, following a nonjury trial.
- Evidence showed driving at high speed and erratic behavior; officer observed bloodshot eyes and impairment.
- Soucy admitted taking prescribed oxycodone for neck injury and flu before detention.
- Field sobriety tests were failed; intoxilyzer read 0.00% BAC, indicating non-alcohol impairment.
- A drug recognition expert found impairment; urine test detected oxycodone and hydrocodone.
- Pills labeled to Soucy were found hidden in the woods; court affirmed the conviction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence to prove impairment while driving | Soucy (Soucy) argues no impairment shown by drugs. | Soucy contends evidence insufficient to prove impairment. | Sufficient evidence supports impairment while operating a vehicle. |
| Can prescription drugs support a finding of OUI | State relies on impairment from prescribed drugs. | Prescription drugs can cause impairment and justify OUI. | Prescription drugs can support an OUI conviction if impairment is shown. |
| Standard of review for sufficiency of evidence | State benefits from favorable view of evidence. | Sufficiency review limits inferences against the defense. | Court reviews evidence in the light most favorable to the State; resolves reasonable inferences for conviction. |
| Role of voluntary intoxication in OUI determination | Involuntary intoxication not required to convict. | N/A | Involuntary intoxication is not required; any impairment suffices. |
Key Cases Cited
- State v. Medeiros, 997 A.2d 95 (Me. 2010) (sufficiency and inference standards for OUI)
- State v. Moores, 910 A.2d 373 (Me. 2006) (reasonable inferences when reviewing sufficiency)
- State v. Smen, 895 A.2d 319 (Me. 2006) (standard for drawing inferences in OUI cases)
- State v. McCurdy, 795 A.2d 84 (Me. 2002) (symptoms of intoxication can support OUI finding)
- State v. Worster, 611 A.2d 979 (Me. 1992) (impairment by intoxicants establishes OUI)
- State v. Bento, 600 A.2d 1094 (Me. 1991) (illicit to require only alcohol; any intoxicant can support OUI)