Pennsylvania v. Hutchins

42 A.3d 302 (2012)

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Pennsylvania v. Hutchins

Pennsylvania Superior Court
42 A.3d 302 (2012)

  • Written by Patrick Speice, JD

Facts

Cory Hutchins (defendant) was driving the speed limit on a flat road on a clear, sunny day. Hutchins’s three daughters were in the car with him. Hutchins inexplicably turned in front of an oncoming car, causing an accident that significantly damaged the cars and injured Hutchins’s daughters. Hutchins admitted to one of the responding police officers, who was trained on the effects of marijuana use, that the accident was his fault because Hutchins was distracted. Hutchins also admitted to using marijuana approximately four hours earlier that day, but no field-sobriety test was conducted because Hutchins left the scene of the accident to travel to the hospital with his daughters. A subsequent blood test revealed the presence of a marijuana metabolite in Hutchins’s blood. Another officer who responded to the accident smelled marijuana in Hutchins’s car and found marijuana while looking for the car’s registration and insurance documentation. Hutchins was charged with driving under the influence of marijuana (DUI). At trial, the responding officer who spoke to Hutchins at the scene opined that Hutchins was under the influence of marijuana at the time of the accident because Hutchins’s pupils were dilated, no other explanation was offered for why Hutchins turned in front of an oncoming car, and Hutchins was oddly calm after having been in a serious accident that left his daughters crying and injured, with one bleeding significantly. No expert testimony was presented regarding the import of Hutchins’s positive blood test. Hutchins was convicted and appealed, arguing that the commonwealth did not prove that he was impaired and could not drive safely.

Rule of Law

Issue

Holding and Reasoning (Olson, J.)

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