Commonwealth v. Plum

21 Pa. D. & C.5th 522
CourtPennsylvania Court of Common Pleas, Lawrence County
DecidedFebruary 8, 2011
Docketno. 865 of 2010
StatusPublished

This text of 21 Pa. D. & C.5th 522 (Commonwealth v. Plum) is published on Counsel Stack Legal Research, covering Pennsylvania Court of Common Pleas, Lawrence County primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Commonwealth v. Plum, 21 Pa. D. & C.5th 522 (Pa. Super. Ct. 2011).

Opinion

COX, J.,

Before the court for disposition is the petition for writ of habeas corpus filed on behalf of the defendant Steven Michael Plum, in which he argues that the commonwealth failed to establish a prima facie case proving that the defendant was in actual physical control of the motor vehicle as is required by the driving under the influence statute, 75 Pa.C.S.A. § 3802.

On April 18, 2010, an automobile was involved in an accident after the driver failed to negotiate a bend on Lawrence Avenue, Ellwood City, Lawrence County, Pennsylvania. The driver drove the vehicle through a wooden utility pole then struck a parked vehicle and rested upon another utility pole. Christian Lample, who was visiting his mother-in-law’s residence, heard a loud noise and went to investigate. He soon noticed a vehicle resting upon a utility pole near a small autobody shop. He ran to the vehicle and arrived approximately 40 to 45 seconds after he heard the noise. Upon arrival at the scene, Mr. Lample noticed the defendant in the driver’s seat of the vehicle with his leg partially on the seat. Mr. Lample did [524]*524not observe anyone else inside or outside of the vehicle. The defendant informed Mr. Lample that he was looking for his cellular phone. Shortly thereafter, members of the Ellwood City Police Department arrived at the scene of the accident and were followed by Trooper Shawn King of the Pennsylvania State Police. Trooper King noticed the defendant emitted a strong odor of alcohol and had bloodshot and glassy eyes. Additionally, the defendant insisted that he was not driving the vehicle and gave inconsistent recounts of the accident, first stating that he did not want disclose the identity of the driver for fear of retaliation and, later, he explained that the owner of the vehicle was driving. As a result of the investigation, the trooper transported the defendant to Ellwood City Hospital for a blood alcohol test to determine if he was intoxicated. The defendant was charged with the following offenses: driving under the influence: general impairment1, driving under the influence: highest rate of alcohol2, 2 counts of driving while operating privilege is suspended or revoked3, required financial responsibility4, driving on roadways laned for traffic5, driving vehicle at safe speed6 and careless driving7.

The defendant has filed this petition for writ of habeas corpus, in which he contends that the commonwealth has failed to establish a prima facie case for driving under the influence as there is no evidence that the defendant was in actual physical control of the vehicle.

[525]*525A petition for writ of habeas corpus is the proper means for testing a pre-trial finding that the commonwealth has presented sufficient evidence to establish a prima facie case. Commonwealth v. Karlson, 674 A.2d 249 (Pa. Super. 1996). In evaluating an accused’s entitlement to pre-trial habeas corpus relief, a trial court must determine whether there is sufficient evidence to make out a prima facie case that the defendant committedthe crime with whichhe or she is charged. Commonwealth v. Hock, 556 Pa. 409, 728 A.2d 943 (1999). In a pre-trial habeas corpus proceeding, as in a preliminary hearing, the commonwealth has the burden of establishing a prima facie case, offering some proof to establish each material element of the offense as charged. Commonwealth v. Owen, 580 A.2d 412 (Pa. Super. 1990). This does not mean that the prosecution must prove the accused guilty beyond a reasonable doubt, but rather, the prosecution must establish “sufficient probable cause” that the accused has committed the offense. Commonwealth v. Prosdocimo, 479 A.2d 1073 (Pa. Super. 1994). The standard for determining whether a defendant is properly held for court is: (a) that the record reveals a prima facie showing that a crime or crimes have been committed; and (b) that the defendant was in some way legally responsible. Liciaga v. Court of Common Pleas of Lehigh County, 523 Pa. 258, 566 A.2d 246 (1989). A prima facie case consists of evidence, read in the light most favorable to the commonwealth, that sufficiently establishes both the commission of a crime and that the accused is probably the perpetrator of that crime. Commonwealth v. Fountain, 811 A.2d 24 (Pa. Super. 2002).

The commonwealth establishes a prima facie case when it produces evidence that, if accepted as true, would [526]*526warrant the trial judge to allow the case to go to a jury. Commonwealth v. Marti, 779 A.2d 1177 (Pa. Super. 2001). The prima facie case merely requires evidence of the existence of each element of the crime charged. Id. Additionally, the evidence is to be reviewed in a light most favorable to the commonwealth and the commonwealth is entitled to reasonable inferences drawn from the evidence. Id. The weight and credibility of the evidence is not a factor at this stage, the commonwealth need only demonstrate sufficient probable cause to believe the person charged has committed the offense. Id.

75 Pa.C.S.A. § 3802 requires the commonwealth to establish that the defendant was in actual physical control of the vehicle. Commonwealth v. Williams, 941 A.2d 14, 27 (Pa. Super. 2008). The court must examine the totality of the circumstances and consider the following factors when determining if the defendant was in actual physical control of the vehicle: “the motor running, the location of the vehicle, and additional evidence showing that the defendant had driven the vehicle.” Id. (quoting Commonwealth v. Woodruff, 668 A.2d 1158, 1161 (Pa. Super. 1995)). The commonwealth is permitted to establish that the defendant was in actual physical control of the vehicle solely through circumstantial evidence, Id. (citing Commonwealth v. Johnson, 833 A.2d 260 (Pa. Super. 2003)). “The concept of‘actual physical control’ involves the control of the movements of either the machinery of a motor vehicle or of the management of the vehicle itself, without a requirement that the entire vehicle be in motion.” Commonwealth v. Grimes, 648 A.2d 538, 544 (Pa. Super. 1994) (citing Commonwealth v. Bobotas, 588 A.2d 518, 521 (Pa. Super. 1991)). Merely demonstrating [527]*527that the defendant was in the vehicle while intoxicated is insufficient to establish that the defendant was in actual physical control of the vehicle. Commonwealth v.

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Related

Commonwealth v. Hock
728 A.2d 943 (Supreme Court of Pennsylvania, 1999)
Commonwealth v. Johnson
833 A.2d 260 (Superior Court of Pennsylvania, 2003)
Commonwealth v. Woodruff
668 A.2d 1158 (Superior Court of Pennsylvania, 1995)
Commonwealth v. Grimes
648 A.2d 538 (Superior Court of Pennsylvania, 1994)
Commonwealth v. Owen
580 A.2d 412 (Supreme Court of Pennsylvania, 1990)
Commonwealth v. Marti
779 A.2d 1177 (Superior Court of Pennsylvania, 2001)
Commonwealth v. Williams
941 A.2d 14 (Superior Court of Pennsylvania, 2008)
Commonwealth v. Karlson
674 A.2d 249 (Superior Court of Pennsylvania, 1996)
Liciaga v. Court of Common Pleas
566 A.2d 246 (Supreme Court of Pennsylvania, 1989)
Commonwealth v. Brotherson
888 A.2d 901 (Superior Court of Pennsylvania, 2005)
Commonwealth v. Bobotas
588 A.2d 518 (Superior Court of Pennsylvania, 1991)
Commonwealth v. Wilson
660 A.2d 105 (Superior Court of Pennsylvania, 1995)
Commonwealth v. Fountain
811 A.2d 24 (Superior Court of Pennsylvania, 2002)
Commonwealth v. Prosdocimo
479 A.2d 1073 (Supreme Court of Pennsylvania, 1984)

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Bluebook (online)
21 Pa. D. & C.5th 522, Counsel Stack Legal Research, https://law.counselstack.com/opinion/commonwealth-v-plum-pactcompllawren-2011.