OWENS V.

STATE
93 Md.App. 162, 611 A.2d 1043
(Court of Special Appeals of Maryland, 1992.)

Procedural History
- District Court:
• Prosecution: The State of Maryland
• Defendant: Christopher Columbus Owens, Jr.
• Judge convicted Owens of DUI without a jury
- Court of Appeals:
• Appellant: Christopher Columbus Owens, Jr.
• Appellee: The State of Maryland
• Court affirms the District Courts conviction

Holding and Disposition

- Holding: Defendant Christopher Owens found guilty of DWI
- Disposition: Affirmed Owen’s conviction for driving under the influence (DUI)

Legal Claim / Cause of Action

- Legal Claim: Driving While Intoxicated

Key Facts
- Owens was found behind the wheel of an automobile parked on a private driveway at night
with the lights on and with the motor running.
- Someone had complained to police about a suspicious vehicle, which turned out to be Owens.
- There was an open beer can in between Owens’ legs and two empty beer cans in the backseat.
- Owens stumbled out of the vehicle. His face was flushed and his eyes were red. He was unable
to recite the alphabet correctly.
- Owens was convicted in District Court by a judge (no jury present)
- Owens does not dispute the fact of drunkenness but rather the place of drunkenness (Driveway
vs. On The Road)
Legal Issue
- Legal Issue: Is drawing an inference of guilt an acceptable means of proving guilt beyond a
reasonable doubt?

Court’s Reasoning
- In Owen’s scenario the circumstances allowed for two reasonable hypotheses:
• 1) He had arrived in the driveway from somewhere else.
• 2) He had gotten into the vehicle and was preparing to drive somewhere.
- The three beer cans found at the scene serve as a “tiebreaker”
• The fact that there was an open can between the defendant’s legs and two empty cans in the
backseat suggests that Owens was on the tail-end of a drinking spell.
• One does not typically drink in the house and then carry the empties out to the car.
• The appellant’s state of consciousness enforces the inference that some significant drinking
had occurred while the appellant was inside the car. (One passes out on the steering wheel
after they drink, not as they begin to drink)
• It’s not a reasonable hypothesis that one would leave the house, get in the car, turn on the
lights, turn on the motor, and then consume enough alcohol to pass out
- The complaint about a “suspicious vehicle” made to police also makes the second hypothesis
unreasonable
• It’s reasonable to infer that the vehicle had been observed driving in some sort of erratic
fashion.
• The call to police complements such a inference.
• This inference does not prove guilt by itself. It simply makes one of two alternative
inferences less reasonable, and its alternative inference thereby more reasonable.