Stevens v. State
129 A.3d 206
| Del. | 2015Background
- On March 17, 2013, Stevens’ car crossed a median, struck a tree, and collided head-on with Melchiore’s vehicle; both cars were totaled and Melchiore smelled alcohol on Stevens’ breath.
- Trooper Gaffney observed signs of intoxication: odor of alcohol, stumbling, slurred speech, and glassy eyes; Stevens twice handed over his car keys unsolicited.
- Stevens left the hospital refusing treatment, ignored police requests to return, and could not identify where he had been coming from when questioned.
- Stevens was charged with DUI (21 Del. C. § 4177) among other offenses; a Court of Common Pleas bench trial found him guilty after denying his motion for judgment of acquittal.
- Superior Court affirmed, rejecting insufficient-evidence and double-jeopardy claims; Stevens appealed raising (1) insufficient evidence and (2) a constitutional equal protection challenge comparing DUI and Reckless Driving–Alcohol Related (RDAR).
- The Delaware Supreme Court affirmed the Superior Court judgment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Sufficiency of evidence to convict of DUI | Stevens: evidence was insufficient to prove impairment beyond a reasonable doubt | State: circumstantial evidence (crash, odor, stumbling, slurred speech, inability to explain origin) proves impairment | Affirmed — viewed in light most favorable to State, a rational trier of fact could find DUI beyond a reasonable doubt |
| Equal Protection challenge comparing DUI and RDAR | Stevens: DUI carries harsher punishment than RDAR for identical conduct, violating equal protection | State: statutes require different elements, so they do not punish identical conduct | Affirmed — statutes contain different elements; no equal protection violation; RDAR is not a lesser included offense |
Key Cases Cited
- Anderson v. State, 21 A.3d 52 (Del. 2011) (deferential review of trial factfinding)
- Lewis v. State, 626 A.2d 1350 (Del. 1993) (defining DUI impairment standard and distinguishing from requirement to be intoxicated)
- Bease v. State, 884 A.2d 495 (Del. 2005) (discussing indicia of intoxication for probable cause)
- Lefebvre v. State, 19 A.3d 287 (Del. 2011) (discussing indicia in probable cause context)
- Wainwright v. State, 504 A.2d 1096 (Del. 1986) (plain error review for unpreserved constitutional claims)
- Stansbury v. State, 591 A.2d 188 (Del. 1991) (applying plain error standard)
- Hughes v. State, 653 A.2d 241 (Del. 1994) (equal protection principle on disparate punishment)
- Johnson v. State, 5 A.3d 617 (Del. 2010) (applying Blockburger test for distinct offenses)
- Michael v. State, 529 A.3d 752 (Del. 1987) (prior discussion that contributed to confusion over lesser-included status)