Carla Juanita Prince was convicted of DUI (first offense, Class A misdemeanor) and reckless driving (Class B misdemeanor) following a jury trial in Franklin County. Her sentences were eleven months and twenty-nine days for DUI, and six months for reckless driving, both suspended except for forty-eight hours of jail time, to be served consecutively. She also faced a one-year driver’s license revocation and a total fine of $360. On appeal, Prince challenged the sufficiency of the evidence supporting her DUI conviction.
The case involved testimony from Deputy Todd Hindman, who observed Prince's erratic driving behavior, including multiple failed attempts to park and striking a curb. Upon stopping her, he noted signs of alcohol influence, such as disheveled clothing, slurred speech, and instability while standing. Prince admitted to consuming four beers but refused certain field sobriety tests, claiming a back injury. Hindman determined she failed the tests she did attempt and subsequently transported her to a medical facility for blood alcohol and drug testing, which she refused. The appellate court affirmed the trial court’s judgments.
Correctional Officer Mike Saint John observed the defendant refuse to sign an implied consent form. During cross-examination, Deputy Hindman noted that it was raining during the defendant's field sobriety tests. Hindman reported that the defendant's finger-to-nose test was close to accurate, but he could not ascertain if impairment was due to alcohol or prescription medication. He also indicated that the odor of alcohol persisted when the defendant exited her vehicle and expressed his belief that she was intoxicated.
Deputy Ross Peterson, who arrived at the scene, detected a strong smell of alcohol on the defendant, observed slurred speech, unsteady balance, droopy eyes, and noted that her pants were unzipped. He remarked on her apparent difficulty in following instructions during the sobriety tasks. After Peterson's arrival, he awaited a wrecker and had no further contact with the defendant.
Saint John, working in the jail's booking area, described the defendant as staggering and off-balance when brought in by Hindman, and he also witnessed her refusal to provide booking information. He documented her belligerent behavior in the jail log, stating she was uncooperative and argumentative. He identified a video recording from the booking area, which had been activated due to her gender, but was unsure about the retention period for the tapes.
Celeste Simmons, the defendant's daughter, testified that she spent the previous night at the defendant’s home, stating that the defendant had not consumed alcohol that day but had the day before. Simmons noted that the defendant appeared fine when she took a phone call for her mother and did not notice any signs of alcohol.
Amy Ingle, the defendant’s daughter-in-law, corroborated that the defendant did not exhibit signs of intoxication during her visit the day before the arrest, confirming she did not smell of alcohol or display slurred speech or erratic behavior when Ingle left around 6:00 to 7:00 p.m.
Ingle denied any drinking on the day of the arrest but admitted that her husband and the defendant had consumed beer the night before until midnight. Ingle suggested that her husband likely drank more than the defendant. The defendant, aged forty-seven at the time of arrest, stated she was on disability due to multiple health issues and was under a doctor's care. She had three to four beers during a family gathering on Friday but claimed not to have drunk alcohol the following Saturday, the day of her arrest. However, she did take pain medications in the morning.
After going to bed around 9:30 or 10:00 p.m., the defendant was awakened by her daughter for a phone call and left for a friend's house. While driving, she noticed police cars, missed her turn, and had a minor incident with a curb. During a traffic stop, she informed the officer that her health issues prevented her from performing field sobriety tests, only attempting the finger-to-nose test. The defendant described the weather as windy and stormy and refused a blood test due to a fear of fainting, claiming the officer did not offer a breathalyzer.
She explained the odor of alcohol in her vehicle as stemming from a spill by her son. The defendant noted it had been about thirty hours since her last beer consumption. Regarding her disheveled appearance during her arrest, she stated she had quickly dressed after being awakened. Although she had taken her medications and consumed alcohol on Friday, she did not believe this constituted a harmful combination. She acknowledged awareness of warnings against mixing alcohol with her medications but denied any difficulties with jail personnel during her arrest, choosing not to answer their questions.
The defendant contends that the evidence supporting her DUI conviction is inadequate, arguing that her completion of field sobriety tasks was impacted by a back injury for which she was receiving medical care. She also highlights the destruction of a videotape from her booking process, claiming this absence indicates a lack of sufficient evidence against her. The defendant asserts it is unfair to be convicted when significant evidence was not preserved for the jury's review.
The reviewing court's role in evaluating evidence sufficiency on appeal is to determine if any rational juror could find the essential elements of the crime beyond a reasonable doubt, as established by legal precedent (Jackson v. Virginia). If the evidence is deemed insufficient, guilty findings can be overturned. However, the trier of fact is responsible for assessing witness credibility and the weight of evidence, and a jury's guilty verdict, supported by the trial judge, implies acceptance of the State's evidence and testimony.
The defendant was convicted under Tennessee Code Annotated section 55-10-401(a), which prohibits driving under the influence of intoxicants or with a blood alcohol concentration of 0.10% or more. Evidence presented included testimony from Deputy Hindman, who noted signs of intoxication such as the odor of alcohol, slurred speech, and instability, corroborated by other officers' observations. Based on the evidence viewed favorably towards the State, the court found sufficient grounds for the jury to convict the defendant. The court ultimately upheld the trial court's judgment, affirming the conviction.
