Challenges to DUI convictions often turn on disputes about when a defendant consumed alcohol and whether the Commonwealth presented sufficient evidence to prove impairment at the time of driving. A recent decision demonstrates how Pennsylvania courts evaluate these arguments and how review focuses on the adequacy of proof rather than credibility disputes. If you are charged with a DUI offense in Pennsylvania, it is smart to meet with a Pennsylvania DUI defense attorney to discuss your options for seeking a favorable outcome.
Facts and Procedural History
It is reported that law enforcement responded to a domestic disturbance in Indiana County in the late afternoon. Officers received information that the defendant had been drinking prior to leaving the scene in a silver vehicle. A trooper traveling along a nearby roadway soon located a vehicle matching the description parked outside a convenience store.
Allegedly, the trooper observed the defendant exit the driver’s side of the vehicle and walk into the store. That alcohol was not sold in the convenience store, which occupied one side of a building shared with a pizza shop. The trooper contacted the defendant inside, directed him outside, and observed multiple signs of impairment, including a staggered gait, the odor of alcohol, and bloodshot eyes.
It is alleged that the defendant was arrested and consented to a blood draw roughly an hour later. Forensic analysis revealed a blood alcohol concentration above 0.25 percent, exceeding the threshold for the highest rate DUI classification. The trial court credited the officers’ testimony, concluded that the defendant drank before driving, convicted him following a bench trial, and imposed a sentence that included incarceration and fines. The defendant appealed, asserting that the evidence showed he drank only after parking his vehicle.
Sufficiency of Evidence in DUI Cases
On appeal, the court applied the standard governing sufficiency challenges, which requires the court to view the evidence in the light most favorable to the Commonwealth. Under this standard, the court does not reweigh the evidence, reconsider credibility findings, or resolve conflicts in testimony. Instead, it asks whether the admitted evidence, if accepted as true, supports each element of the offense beyond a reasonable doubt.
Section 3802(c) of the Vehicle Code prohibits driving after consuming enough alcohol to produce a blood alcohol concentration of 0.16 percent or higher within two hours of driving. The statute permits the Commonwealth to prove its case entirely through circumstantial evidence. The trial evidence showed that the defendant left a residence after drinking, operated a vehicle on a public roadway, entered a business establishment that did not sell alcohol, and exhibited clear signs of impairment shortly thereafter. The blood test result, taken within the statutory two-hour window, further supported the inference that the defendant consumed alcohol before driving.
The court found that the defendant’s arguments did not challenge the sufficiency of the evidence but instead attacked the trial court’s credibility determinations. Because the defendant failed to preserve a weight-of-the-evidence claim through a post-sentence motion, the issue was waived. Even if preserved, the court explained that it is trial courts, not appellate courts, that are responsible for assessing witness credibility. The record contained competent evidence supporting the conviction, and the testimony established the statutory elements. For these reasons, the court affirmed the judgment of sentence.
Speak with a Capable Pennsylvania DUI Defense Attorney
If you are facing DUI charges in Pennsylvania, it is essential to understand how the courts evaluate evidence and how recent decisions may affect your case. Attorney Zachary B. Cooper is a capable Pennsylvania DUI defense attorney who can advise you of your rights and formulate compelling arguments on your behalf. To schedule a confidential consultation, contact Attorney Cooper at (215) 542-0800 or reach out through the online contact form.