Pennsylvania v. Hutchins

Brief Fact Summary.

Appellant and Mr. White got into a car accident. Mr. Mays and Mr. Tate, Pennsylvania Troopers, thought Appellant’s behavior was strange at the scene. Further, Appellant admitted to smoking marijuana earlier that day. Eventually, Mr. Tate conducts a sobriety test and arrests Appellant.

Synopsis of Rule of Law.

When evaluating whether one is driving to a degree that impairs the individual’s ability to safely drive, the court must evaluate the totality of the circumstances.

Facts.

Christopher White was traveling east on Jonestown Road when Appellant’s vehicle turned in front of him. Appellant had his three young daughters inside his vehicle. Mr. White testified that there were not any hills or slopes on the road, it was a sunny day, and he was driving approximately 45 mph, the speed limit. When the cars struck, the impact deployed the airbags and Mr. White’s car was totaled. Trooper David Mays was dispatched to the scene. At the scene, he searched Appellants vehicle for his registration and license and smelled an odor of marijuana. Also, he found a Camel cigarette in the left driver side door pocket that contained marijuana. Appellant admitted to Mr. Mays that the accident as his fault. Also at the scene was Trooper Nathan Tate who noted Appellant was very calm, so he asked him if he was under the influence of alcohol. Appellant said he had not drank alcohol, but admitted to smoking marijuana earlier in the day. Based on Mr. Tate’s experience, he believed Appellant was under the influence of marijuana, as Appellants pupils were constricted, he seemed fatigued, and had an inability to concentrate. Field sobriety test were not performed on Appellant because he left the scene to take his three daughters to the hospital. Mr. Tate went to the hospital, conducted the sobriety test, and arrested Appellant. Appellant consented to a blood test, which indicated that Appellant did not have any alcohol in his blood. However, Appellant’s blood sample contained 43 ng/ml of carboxy acid, a metabolite of the marijuana plants. Likewise, it is uncontested that Appellant had .63 grams of marijuana in his vehicle at the time of the accident.

Issue.

Whether the evidence sufficiently indicates that the Appellant was driving to a degree that impairs the individual’s ability to safely drive, as required by the state statute.

Held.

Yes, based on the totality of the circumstance, the evidence does establish that Appellant’s driving abilities were sufficiently impaired to constitute a violation of the statute.

Discussion.

Appellant claims that his admission to smoking marijuana earlier that day alone is insufficient to hold a conviction that he could not drive safely. The court agreed with Appellant and indicated that to meet the causation element, the State must produce expert testimony. Here, Appellants blood system only indicated that there was a 43 ng/ml of carboxy acid metabolite of the marijuana plant in his body. The court noted that metabolite is not evidence of active marijuana, but of marijuana waste. Therefore, the State failed to establish that Appellant was under the influence of marijuana at the time of the accident. Nevertheless, the court disagrees that the only evidence against Appellant is his admission of smoking marijuana earlier that day. Here, Mr. Mays, who is trained to detect marijuana smelled the marijuana and recovered raw marijuana the day of the accident. Likewise, both Troopers noted Appellants unusual behavior. Therefore, based on the totality of the circumstances, there was sufficient evidence to establish Appellant’s conviction.