State of Alabama v. Samantha Kaye Shiver (Appeal from Houston Circuit Court: CC-22-1655)

CourtCourt of Criminal Appeals of Alabama
DecidedNovember 8, 2024
DocketCR-2023-0604
StatusPublished

This text of State of Alabama v. Samantha Kaye Shiver (Appeal from Houston Circuit Court: CC-22-1655) (State of Alabama v. Samantha Kaye Shiver (Appeal from Houston Circuit Court: CC-22-1655)) is published on Counsel Stack Legal Research, covering Court of Criminal Appeals of Alabama primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State of Alabama v. Samantha Kaye Shiver (Appeal from Houston Circuit Court: CC-22-1655), (Ala. Ct. App. 2024).

Opinion

Rel: November 8, 2024

Notice: This opinion is subject to formal revision before publication in the advance sheets of Southern Reporter. Readers are requested to notify the Reporter of Decisions, Alabama Appellate Courts, 300 Dexter Avenue, Montgomery, Alabama 36104-3741 ((334) 229-0650), of any typographical or other errors, in order that corrections may be made before the opinion is published in Southern Reporter.

Alabama Court of Criminal Appeals OCTOBER TERM, 2024-2025 _________________________

CR-2023-0604 _________________________

State of Alabama

v.

Samantha Kaye Shiver

Appeal from Houston Circuit Court (CC-22-1655)

McCOOL, Judge.

The State of Alabama ("the State") has appealed the Houston

Circuit Court's dismissal of a complaint charging Samantha Kaye Shiver

with driving under the influence of alcohol ("DUI"). See § 32-5A-191, Ala. CR-2023-0604

Code 1975. For the reasons set forth herein, we reverse the circuit court's

judgment and remand the case for that court to reinstate the complaint.

Facts and Procedural History

On November 5, 2021, Shiver was issued a Uniform Traffic Ticket

and Complaint ("UTTC") charging her with violating § 32-5A-191(a)(5),

which prohibits a person from driving a vehicle while "[u]nder the

influence of any substance which impairs the mental or physical faculties

of such person to a degree which renders him or her incapable of safely

driving." Although § 32-5A-191(a)(5) prohibits a person from driving a

vehicle while under the influence of "any substance," subsections (a)(1)-

(a)(4) of that statute expressly prohibit a person from driving a vehicle

while under the influence of alcohol or a controlled substance. Thus, this

Court has previously held that § 32-5A-191(a)(5) "was enacted to cover

those situations in which the defendant's mental and/or physical faculties

are impaired by some substance other than alcohol or a controlled

substance." Sturgeon v. City of Huntsville, 599 So. 2d 92, 94 (Ala. Crim.

App. 1992) (emphasis added).

In August 2022, Shiver was brought to trial in the Houston District

Court. "Mere seconds before trial was commenced" (R. 6), the State

2 CR-2023-0604

moved to amend the complaint so that, instead of charging Shiver with

DUI under § 32-5A-191(a)(5), it charged her with DUI under § 32-5A-

191(a)(2), which prohibits a person from operating a vehicle while

"[u]nder the influence of alcohol." The district court allowed the

amendment over Shiver's objection, and she was subsequently convicted

of DUI under § 32-5A-191(a)(2).

Shiver appealed to the circuit court for a trial de novo and then filed

a motion to dismiss the complaint, arguing that the district court had

improperly allowed the State to amend the charge against her. In

support of her motion, Shiver argued that "it is axiomatic that [a] charge

cannot be amended … if the amended offense is a different offense," and,

according to Shiver, § 32-5A-191(a)(2) and § 32-5A-191(a)(5) "are

completely separate offenses." (C. 67, 69.) Shiver also argued that she

"was never put on notice or informed, except mere seconds before trial in

district court, that she would have to defend a charge … that was related

to and/or involved alcohol because the UTTC charged her with violating

[§ 32-5A-191(a)(5)]." (C. 68.)

The circuit court held a hearing on Shiver's motion, at which the

State argued that § 32-5A-191(a)(2) and § 32-5A-191(a)(5) are not

3 CR-2023-0604

different offenses but, rather, alternative means of proving the same

offense, i.e., DUI. The State also argued that Shiver was aware "that it

was alcohol that was involved" and was therefore "on notice as far as

what the charge was as to DUI." (R. 9.) Thus, according to the State, the

district court had properly allowed it to amend the charge against Shiver.

On August 10, 2023, the circuit court dismissed the complaint,

finding that "the amendment to the complaint … operated to charge an

offense not contemplated by the original complaint, and [Shiver] was not

reasonably placed on notice as to the charge she would be required to

defend." (C. 88.) The State filed a timely notice of appeal.

Discussion

On appeal, the State contends that the circuit court erred by

dismissing the complaint against Shiver, arguing that the court

erroneously concluded that the DUI charge had been improperly

amended. We agree.

Rule 13.5(a), Ala. R. Crim. P., states:

"A charge may be amended by order of the court with the consent of the defendant in all cases, except to change the offense or to charge new offenses not contemplated by the original indictment. The court may permit a charge to be amended without the defendant's consent, at any time before verdict or finding, if no additional or different offense is

4 CR-2023-0604

charged and if the substantial rights of the defendant are not prejudiced."

(Emphasis added.)

Section 32-5A-191(a) states:

"A person shall not drive or be in actual physical control of any vehicle while:

"(1) There is 0.08 percent or more by weight of alcohol in his or her blood;

"(2) Under the influence of alcohol;

"(3) Under the influence of a controlled substance to a degree which renders him or her incapable of safely driving;

"(4) Under the combined influence of alcohol and a controlled substance to a degree which renders him or her incapable of safely driving; or

"(5) Under the influence of any substance which impairs the mental or physical faculties of such person to a degree which renders him or her incapable of safely driving."

In Stone v. City of Huntsville, 656 So. 2d 404 (Ala. Crim. App. 1994),

this Court explained that "[t]he five subsections of § 32-5A-191(a) provide

'alternative methods of proving' the 'single offense of driving under the

influence.' " Stone, 656 So. 2d at 413 (quoting Bartlett v. State, 600 So.

2d 336, 342 (Ala. Crim. App. 1991)) (emphasis added). Thus, the State

5 CR-2023-0604

correctly argues that it did not charge Shiver with a different offense by

amending the complaint so that it alleged a violation of § 32-5A-191(a)(2)

instead of § 32-5A-191(a)(5). That fact does not end our analysis, though,

because Rule 13.5 provides that a charge may be amended without the

defendant's consent "if no additional or different offense is charged and

if the substantial rights of the defendant are not prejudiced." (Emphasis

added.)

The circuit court found that Shiver's substantial rights had been

prejudiced by the amended charge because, according to the court, she

had not received reasonable notice that the State would be prosecuting

her under § 32-5A-191(a)(2) instead of § 32-5A-191(a)(5), which was the

charge cited in the UTTC. However, that finding was based on the fact

that Shiver had received notice of the amended charge "[m]ere seconds"

before her district-court trial began. In other words, the circuit court

dismissed the complaint against Shiver based on what the court

perceived to be an error in the district-court proceedings.

A defendant who is convicted of an offense in district court has the

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Related

Bartlett v. State
600 So. 2d 336 (Court of Criminal Appeals of Alabama, 1992)
Ex Parte Sorsby
12 So. 3d 139 (Supreme Court of Alabama, 2007)
Stone v. City of Huntsville
656 So. 2d 404 (Court of Criminal Appeals of Alabama, 1994)
Ex Parte Boswell
558 So. 2d 918 (Supreme Court of Alabama, 1990)
Sturgeon v. City of Vestavia Hills
599 So. 2d 92 (Court of Criminal Appeals of Alabama, 1992)
State v. Petty
711 S.E.2d 509 (Court of Appeals of North Carolina, 2011)
State v. . Brittain
57 S.E. 352 (Supreme Court of North Carolina, 1907)
State v. . Crandall
33 S.E.2d 861 (Supreme Court of North Carolina, 1945)
Louisville & Nashville Railroad v. Lancaster
121 Ala. 471 (Supreme Court of Alabama, 1898)
State v. Crandall
225 N.C. 148 (Supreme Court of North Carolina, 1945)
Casey v. Bingham
265 So. 3d 288 (Court of Civil Appeals of Alabama, 2018)

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State of Alabama v. Samantha Kaye Shiver (Appeal from Houston Circuit Court: CC-22-1655), Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-of-alabama-v-samantha-kaye-shiver-appeal-from-houston-circuit-alacrimapp-2024.