Peters v. State

Opinion

2026 WL 1758005

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NOTICE: UNPUBLISHED OPINION

NOTICE This is a summary disposition issued under Alaska Appellate Rule 214(a). Summary dispositions of this Court do not create legal precedent. See Alaska Appellate Rule 214(d).

Court of Appeals of Alaska.

Paul Charles PETERS, Appellant,

v.

STATE of Alaska, Appellee.

Court of Appeals No. A-14497

June 17, 2026

Appeal from the Superior Court, Fourth Judicial District, Fairbanks, Thomas I. Temple, Judge. Trial Court No. 4FA-23-02041 CR

Attorneys and Law Firms

Courtney Lewis, Attorney at Law, under contract with the Public Defender Agency, and Terrence Haas, Public Defender, Anchorage, for the Appellant. Donald Soderstrom, Assistant Attorney General, Office of Criminal Appeals, Anchorage, and Stephen J. Cox, Acting Attorney General, Juneau, for the Appellee.

Before: Allard, Chief Judge, and Wollenberg and Beach, Judges.

SUMMARY DISPOSITION

Star page 1*1 Paul Charles Peters was convicted, after a jury trial, of first-degree vehicle theft after he drove a pickup truck without the owner's permission.¹ Peters now appeals, arguing that the evidence was insufficient to support his conviction.

Peters's conviction was based upon the following facts.² The truck owner's son (who was an authorized user) parked the truck in the late afternoon and left the keys in the ignition. That evening, the truck was gone. The owner's son then contacted the owner and other authorized users, but none of them knew where the truck was. They then contacted the police and began searching for the truck. The truck was found the next morning parked near a residence with a bicycle in the truck bed. (Prior to being stolen, the truck had no bicycle in its bed.) Testimony at trial established that Peters often visited the neighborhood and he had been seen riding the bicycle that was found in the truck bed.

When troopers contacted Peters about the stolen truck, he confessed to taking the truck, driving it around, and then parking it outside an acquaintance's residence in the neighborhood. Peters claimed he was heavily intoxicated when he stole the truck, and a trooper noted that he still appeared to be intoxicated when the troopers spoke with him the morning after the theft. When asked where the keys to the stolen vehicle were, Peters stated they were in his acquaintance's residence. Troopers then went to that residence and obtained the keys to the stolen truck as well as a lanyard that was also in the truck prior to its theft. Peters did not have permission to use the truck.

On appeal, Peters argues that this evidence was insufficient because his intoxication rendered his confession unreliable and because no one saw him drive the vehicle.

But when evaluating the sufficiency of the evidence to support a conviction, we are required to view the evidence in the light most favorable to the verdict.³ Viewing the evidence in that light, we conclude that a fair-minded juror could reasonably find that Peters's confession was reliable despite his intoxication.⁴ Peters's confession was also corroborated by the stolen keys being found where he said they would be and the presence of Peters's bicycle in the bed of the truck after it was stolen. We therefore conclude that the evidence was sufficient for a reasonable juror to find that Peters stole the vehicle despite the fact that no one saw him driving it.

Star page 2*2 The judgment of the superior court is AFFIRMED.

Footnotes

1

AS 11.46.360(a)(1).

2

Because Peters challenges the sufficiency of the evidence, we present the facts in the light most favorable to the verdict. Johnson v. State, 188 P.3d 700, 702 (Alaska App. 2008) (requiring an appellate court reviewing the sufficiency of the evidence to view the evidence — “and all reasonable inferences to be drawn from that evidence” — in the light most favorable to the jury's verdict).

3

Id.

4

Peters cites Hampton v. State for the proposition that intoxication can render confessions unreliable. Hampton v. State, 569 P.2d 138, 144 (Alaska 1977). But Hampton dealt with intoxication affecting a defendant's ability to knowingly and intelligently waive his right to silence — which is distinct from the factual reliability of a confession. Id. at 142-43. And to the extent Hampton’s logic is applicable, the fact that Peters provided coherent answers to the trooper's questions and that his confession was consistent with the timeline of the theft and corroborated by physical evidence (including the location of the stolen keys) was sufficient to allow a reasonable juror to find this confession to be reliable.

End of Document