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State v. Pamela Scuderi
Citation: Not availableDocket: 01C01-9803-CC-00135
Court: Court of Criminal Appeals of Tennessee; January 11, 1999; Tennessee; State Appellate Court
Original Court Document: View Document
Cecil W. Crowson, Appellate Court Clerk, recorded the case against Pamela Jean Scuderi, convicted of driving under the influence (DUI) in Rutherford County, Tennessee. Scuderi received a sentence of eleven months and twenty-nine days, with forty-eight hours in jail and a $350 fine. In her appeal, she contested the sufficiency of the evidence supporting her conviction. Key facts indicate that, after consuming three glasses of wine during dinner with her family, Scuderi was a passenger in a vehicle driven by Michael Calloway, who was subsequently arrested for DUI. When Scuderi attempted to exit the car to check on Calloway, Officer Keith Sanders intervened as she moved into the driver's seat. Although she admitted to drinking and taking prescription medication, Officer Sanders acknowledged he did not observe her in control of the vehicle as it was still running. The appeal centers on the argument that the evidence was insufficient to demonstrate that Scuderi was in physical control of the automobile. The court reviewed the record, including a Statement of the Evidence approved by involved parties, ultimately vacating the conviction based on insufficient evidence to support the jury's verdict. In evaluating an appeal regarding the sufficiency of evidence for a conviction, the standard requires reviewing the evidence in the light most favorable to the prosecution, without reweighing or reevaluating it. The court must consider all reasonable inferences drawn from the evidence, as established in Jackson v. Virginia and State v. Cabbage. Under Tennessee law, it is illegal for anyone to drive or control an automobile while under the influence of an intoxicant (T.C.A. 55-10-401(a)). The Tennessee Supreme Court has interpreted the DUI statute broadly, allowing for a totality of circumstances approach to determine if a defendant had physical control of a vehicle, evaluating factors such as the defendant's location relative to the vehicle, the ignition key's position, and the operational capability of the vehicle. In this case, evidence revealed that the defendant was in the back seat of her owned car and moved to the front seat to exit through the driver's door. However, an officer testified that she did not touch the steering wheel or gear shift. Given this context and viewing the evidence favorably for the state, the court concluded that there was insufficient evidence to prove beyond a reasonable doubt that the defendant was in physical control of the vehicle. Consequently, the conviction was vacated. The court also noted its reliance on the approved Statement of the Evidence, implying that any additional incriminating evidence not included in this statement could not be considered.