People often think of DUI charges as arising out of direct evidence that a person operated a vehicle while intoxicated, but in many instances, the prosecution’s evidence is solely circumstantial. While circumstantial evidence is sufficient to convict a person for a crime, a conviction that rests solely on information from the defendant, like an admission, is improper pursuant to the corpus delicti rule. In a recent opinion, a Pennsylvania court explained the corpus delicti rule and its implication in DUI cases. If you are accused of operating a vehicle while intoxicated, it is advisable to speak with an experienced Pennsylvania DUI defense attorney as soon as possible to evaluate your options.
The Defendant’s Arrest
Allegedly, the police responded to reports of a two-car accident. When they arrived at the scene, all of the parties involved had exited their vehicles. The police spoke with the defendant’s friend, who smelled of alcohol and was unsteady on his feet. Per the arresting officer, the defendant’s friend was extremely intoxicated and would not have been able to operate a vehicle in his condition.
It is reported that the officer spoke with the defendant as well, who stated that he was driving at the time of the accident due to his friend’s intoxication. The defendant also smelled like alcohol, had bloodshot eyes, and was slurring his speech. The officer asked him to submit to field sobriety and breath tests, and he declined. He was charged with and convicted of DUI, after which he appealed.
The Corpus Delicti Rule
On appeal, the defendant argued that the corpus delicti rule applied and, therefore, his conviction should be vacated. Under Pennsylvania law, the corpus delicti rule states that a criminal conviction will not be upheld if it is based solely on an out-of-court statement made by the accused. Further, the rule provides that a case may not proceed to trial absent independent evidence of a crime. In other words, the Commonwealth must provide the corpus delicti or “body of the crime,” which is evidence that criminal conduct occurred, causing an injury or loss.
The court explained, though, that the identity of the party that committed the unlawful act is not part of the corpus delicti. This means that to establish that a DUI crime was committed, the Commonwealth does not need to establish the identity of the actor but merely must prove that a motor vehicle was operated under the influence of alcohol. In the subject case, the court found that the Commonwealth presented sufficient circumstantial evidence of the commission of a DUI offense, establishing the corpus delicti for DUI. Thus, the trial court did not err in admitting the defendant’s statement, and his conviction was upheld.
Speak to a Capable DUI Defense Attorney in Pennsylvania
DUI defendants have rights, including the right against self-incrimination. If you were arrested for a DUI crime based on admission to the police, you may be able to avoid a conviction and should speak to a lawyer. Zachary B. Cooper is a capable Pennsylvania DUI defense attorney who can advise you of your rights and help you to seek the best outcome possible under the facts surrounding your arrest. You can contact Mr. Cooper at (215) 542-0800 or via the form online to set up a meeting.