Bell v. Dunlap

CourtSuperior Court of Maine
DecidedJune 23, 2014
DocketKENap-13-27
StatusUnpublished

This text of Bell v. Dunlap (Bell v. Dunlap) is published on Counsel Stack Legal Research, covering Superior Court of Maine primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Bell v. Dunlap, (Me. Super. Ct. 2014).

Opinion

l N1 ERED AUG 0 8 20\4

STATE OF MAINE SUPERIOR COURT KENNEBEC, SS. CNILACTION DOCKET NO. AP-13-27 bHN- f£1'} 0~ -~3-JZ+ SAMUEL BELL,

,.,E!fitioner v. ORDER

MATTHEW DUNLAP, SECRETARY OF STATE,

Respondent

Before the court is a Rule 80(C) petition for rev1ew of final agency action

pursuant to 5 M.R.S.A. § 11001 et seq.

In March of 2013, The Bureau of Motor Vehicles (BMV) notified Mr. Bell that his

license would be suspended for a period of ninety days because he operated a motor

vehicle with a blood alcohol content (BAC) of 0.08% or more in February of 2013. The

petitioner, through counsel, filed a timely appeal and a stay was placed on the

suspension pending a hearing. A hearing was conducted, at which time the issue was

whether the petitioner was operating a motor vehicle and whether at the time of the

alleged operation, his BAC exceeded 0.08%. The hearing officer denied the appeal

finding that attempted operation" was not an issue and held that Mr. Bell was actually 11

11 operating" a motor vehicle and that the breath test was an accurate reflection of his

alcohol level at the time of the operation. In July of 2013, the BMV issued a stay of the

suspension pending the outcome of this appeal.

A person commits the criminal offense of operating under the influence if he

operates a motor vehicle while under the influence of intoxicants or while having an

alcohol level of 0.08 grams or more of alcohol per 100 milliliters of blood or 210 liters of

breath. 29-A M.R.S.A. § 2411. To assist in the enforcement of said law, the Secretary of State shall immediately suspend the license of a person determined to have operated a

motor vehicle with an excessive alcohol level. The Secretary of State may stay the

suspension until a hearing is held. The scope of the hearing must include whether the

person operated a motor vehicle with an excessive alcohol level and whether there was

probable cause to believe that the person was operating a motor vehicle with an

excessive alcohol level. 29-A M.R.S.A. § 2453. It is Petitioner's assertion that he was not

operating a motor vehicle and that the State improperly shifted the burden of proving

the reliability of the breath test to the Petitioner.

Taking the second issue first, the court is satisfied that the probable cause found

by the officer that Petitioner was impaired along with Petitioner's admission that he did

not drink prior to being found by the officer does not shift the burden of proof

notwithstanding the test of 0.08% and a possible margin of error that could lower it

below the minimum requirement.

The court is asked to provide the legal definition of the term "operation" and the

statutory phrase "operation of a motor vehicle" and apply it to the facts of this case. In

doing so, the court is bound by the findings of fact made by the hearing officer. The

hearing officer concluded from the evidence presented at the hearing that Mr. Bell was

found by the law enforcement officer sitting in the driver's seat of a vehicle owned by

and registered to him. The engine was running. Mr. Bell had his seat belt on and he

had a hand on the steering wheel. When asked his intention, he advised, "We're

waiting for a friend and then we are leaving." From these facts, and with the addition

of the Petitioner's statement of intending to leave when a friend arrived, the examiner

concluded that there was probable cause to believe that Mr. Bell was "operating" the

motor vehicle.

2 First, it is important for the court to note that the hearing examiner made it clear

that she was not finding probable cause that ~. Bell was "attempting" to operate a

motor vehicle. Had she done so, she would have had to find a substantial step toward

the operation of the motor vehicle. 17-A M.R.S.A. § 152. Noteworthy is that she found

operation in the absence of any step at all, let alone a substantial step. Applying that

reasoning, a person doing absolutely nothing can be found to have been doing

something but not found to be attempting to do something.

In the instant situation,~. Bell was not doing anything. 1However, he expressed

an intent to operate the motor vehicle by leaving at a future event. A Law Court

decision which clearly is good law is instructive: State v. Sullivan, 146 Me. 381 (1951).

The language in that case notes the distinction between the operation of a car and the

attempt to operate as dictated by the legislature. Sullivan held that to operate a motor

vehicle is the same as to drive it.

It usually means that a person must so manipulate the machinery that the power of the motor is applied to the wheels to move the automobile forward or backward. The starting of the motor, however, maybe under existing circumstances be sufficient, if there is the intention to move the car.

ld. (emphasis added). The Court went further to say, "Where an attempt to operate is

charged, there must be an intent to commit the offense of operating. Unless the acts

done were done under the influence of liquor, no offense is committed." ld.

The State argues that Sullivan stands for the proposition that the court may take

into consideration the intention of the accused. Indeed, in the present case, the only

element adding to circumstances without an affirmative act on the part of~. Bell, is

the intent for future operation. It is important that the court note that the addition of

the intention to move the car as described in the Sullivan case, only exists where there is 1 Unless sitting in the vehicle is doing something?

3 an affirmative act, in that case "starting of the motor." In other words, there must be

some evidence that the starting of the motor was done with the intention to move the

car. This is found in cases where persons are found asleep in the car or simply resting

in a car to keep warm. In the absence of some effort by the Petitioner to manipulate any

part of the mechanical or electrical machinery of the automobile, the intent is not

relevant.

It is fundamental that operating a motor vehicle while impaired is not a criminal

offense requiring a culpable state of mind other than the intent to operate the motor

vehicle and that it must have been voluntary. The particularly affirmative acts taken by

a defendant must be done intentionally or knowingly.

The court has examined every decision cited by the parties to this proceeding as

well as some additional cases from multiple jurisdictions. State v. Henderson, 416 A.2d

1261 (1980), was an attempt case finding that accelerating the engine while seated in the

driver's seat constituted a substantial step toward operatio!1 of the vehicle. Citing

Sullivan, it says there was an attempt to operate as charged, and that unless the acts

constituting a substantial step toward operation were done with the intent to operate,

no offense is committed.

It was stated in an earlier case, State v. Howard, 139 A.2d 273 (1942), a case

involving a person who was sitting behind the steering wheel with the motor running

with the car in gear and both the rear wheels spinning while the front end of the motor

was suspended in the air five or six inches so that the turning of the steering wheel

could not control the direction or course of the motor vehicle. It cites People v. Domagala,

123 Misc. 757, 206 N.Y.S. 288, holding that the mere starting of a motor vehicle was

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Related

State v. Deschenes
2001 ME 136 (Supreme Judicial Court of Maine, 2001)
People v. Pomeroy
355 N.W.2d 98 (Michigan Supreme Court, 1984)
State v. Sullivan
82 A.2d 629 (Supreme Judicial Court of Maine, 1951)
State v. Webb
210 N.W. 751 (Supreme Court of Iowa, 1926)
State v. Storrs
163 A. 560 (Supreme Court of Vermont, 1933)
State v. Henderson
416 A.2d 1261 (Supreme Judicial Court of Maine, 1980)
People v. Domagala
41 N.Y. Crim. 513 (New York County Courts, 1924)
Commonwealth v. Clarke
254 Mass. 566 (Massachusetts Supreme Judicial Court, 1926)
Commonwealth v. Uski
160 N.E. 305 (Massachusetts Supreme Judicial Court, 1928)

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Bluebook (online)
Bell v. Dunlap, Counsel Stack Legal Research, https://law.counselstack.com/opinion/bell-v-dunlap-mesuperct-2014.