State v. David Eaton

Citation: Not availableDocket: 02C01-9802-CR-00043

Court: Court of Criminal Appeals of Tennessee; October 25, 1999; Tennessee; State Appellate Court

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David B. Eaton was indicted for multiple offenses, including driving under the influence (DUI) and leaving the scene of an accident, but was convicted only for leaving the scene. The trial court sentenced him to eleven months and twenty-nine days in the Shelby County Workhouse, with ninety days to be served and the remainder suspended under supervised probation. Eaton was also fined $1,000. The appeal centered on the sufficiency of the evidence to support the conviction.

On June 1, 1996, Eaton struck Aline Turner's vehicle from behind while she was stopped at a traffic light in Memphis. After the collision, he approached her car but left without providing assistance when she indicated she was not okay. Memphis police officer John Bynum Cobb witnessed the incident, saw Eaton leave the scene, and attempted to pursue him with his partner, Joe Newborn. Despite the officers' efforts to stop Eaton, which included activating lights and sirens, he initially did not comply until traffic congestion hindered his progress.

Upon stopping Eaton, officers noted signs of impairment: slurred speech, bloodshot eyes, and the smell of alcohol. Eaton admitted to consuming Jack Daniels. A DUI technician also suggested that Eaton might be under the influence of substances beyond alcohol, as he mentioned taking medication for depression. Although initially consenting to a breathalyzer test, Eaton later withdrew his consent. The defense presented Dr. John Purvis Milnor, III, who argued that Eaton was experiencing hypoglycemia, which could cause symptoms similar to intoxication, but did not rule out the possibility of functional behavior in such a state. The appellate court concluded that the evidence was sufficient to support the conviction for leaving the scene of the accident.

The defendant, under medical care for heart palpitations since June 1, 1996, claimed he experienced flu-like symptoms and could not remember the accident. On appeal, the state must be viewed in the strongest light with reasonable inferences drawn from the evidence. The jury determines witness credibility and conflicts in testimony. The sufficiency of evidence is assessed to see if a rational trier of fact could find the essential crime elements proven beyond a reasonable doubt. The defendant was convicted of leaving the scene of an accident under Tenn. Code Ann. 55-10-101, which requires a driver to 'knowingly' flee. The defendant argued that he could not have acted knowingly during a hypoglycemic episode, but the state presented evidence indicating his behavior was inconsistent with such an episode and that he was aware during the incident. The jury found the state’s evidence credible, supporting the conclusion that the defendant acted knowingly. Regarding injury, the defendant contended there was no proof of harm to Aline Turner, the other party involved. However, Ms. Turner testified to experiencing pain after the accident, corroborated by Officer Washington's account of an ambulance being called for her treatment. This was deemed sufficient to establish injury as required by the statute. Consequently, the appeal was denied, and the conviction affirmed.