Washington Appellate Court Holds Circumstantial Evidence of DUI Provides Sufficient Grounds for a Suspect’s Confessions to be Admitted into Evidence

If you are charged with a crime, whether or not you are convicted largely depends on what evidence the state is permitted to use against you at trial. Under Washington law, the state must set forth independent evidence of a crime before any confessions made by a suspect may be considered as evidence of guilt. In State of Washington v. Abdirauf A. Isse, the Court of Appeals of the State of Washington held that circumstantial evidence that a suspect was driving a vehicle while intoxicated was sufficient evidence to support a DUI charge, and therefore, the suspect’s statements that he was driving the vehicle were admissible. If you were charged with a DUI, it is essential to your defense to retain an experienced Washington DUI defense attorney to analyze the facts of your case and what defenses you can assert against the charges you face.

Facts of the Case

Allegedly, a police officer responded to the scene of a one-vehicle accident that occurred on an interstate highway. The suspect and a tow truck driver were present at the scene upon the officer’s arrival. The suspect stated he hit black ice and lost control of the vehicle. He retrieved the vehicle registration upon request, but stated the car was registered to his cousin. The suspect did not have a license. Upon realizing the vehicle would be towed, the suspect allegedly became angry and began to yell at the responding officer. The officer observed an odor of alcohol on the suspect’s breath and began to investigate the suspect for suspicion of DUI. During the investigation the suspect spit on several police officers. The suspect was subsequently charged with third degree assault and DUI. Prior to his trial, the suspect moved to suppress any statements he made during his arrest, which the court denied. Following the state’s presentation of its case, the suspect moved to dismiss the DUI charge, which the court denied as well. The suspect was convicted on both charges. He subsequently appealed his DUI charge.

Ruling of the Court of Appeals of The State of Washington

On appeal, the court held that the State produced sufficient evidence to show the “corpus delicti” of the suspect’s DUI charge and affirmed the suspect’s conviction. The court explained that the purpose of the doctrine of corpus delicti is to protect suspects from being convicted due to false admissions by requiring evidence of the crime independent of any confession. The court went on to note that the state must set forth facts that would support a logical conclusion the suspect committed the crime. In this case, the state was required to produce evidence that the suspect was driving the vehicle involved in the accident while he was under the influence of alcohol.

The court declined to define the doctrine of corpus delicti as either an evidentiary rule regarding whether adequate independent evidence of a crime exists to allow the admission of a confession into evidence as asserted by the state, or a rule regarding the sufficiency of the evidence as asserted by the suspect. Rather, the court held that the state set forth independent evidence of the suspect driving while intoxicated regardless of which standard applied. The court declined to adopt the suspect’s reasoning that his mere presence at the scene was not sufficient evidence that he was driving the subject vehicle. The court also rejected the suspect’s argument that the fact that he was not the registered driver and did not have a license supported his innocence. The court held the evidence regarding the circumstances surrounding the accident, including the location where the accident occurred and the suspect’s familiarity with the vehicle and its contents, supported the conclusion he was driving the vehicle. As such, the court held the state met the burden of proof the suspect was driving while intoxicated, independent of his admission.

Retain an Experienced Washington Criminal Defense Attorney

If you are charged with a DUI it is essential to know your rights. It is in your best interest to meet with an experienced DUI defense attorney as soon as you can to discuss a plan to defend the charges you face and what evidence the prosecution may attempt to use against you.  The seasoned criminal defense attorneys of The Law Offices of Smith and White will provide an aggressive defense to the charges you face and will work tirelessly to help you obtain a favorable result. Contact our offices at 253-203-1645 or via the online form to setup a consultation.

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You’ve Been Pulled Over for a DUI, Now What…, March 30, 2017, The Law Offices of Smith & White Blog

 

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