People v. MartinAnnotate this Case
Defendant was indicted on one count of aggravated drinking under the influence ("DUI") when he was involved in a car accident that killed two people and subsequent tests revealed that his blood contained no alcohol or controlled substances, but his urine contained methamphetamine and amphetamine. At issue was whether the appellate court erred in holding that the state failed to prove that defendant was guilty of aggravated DUI where it presented no evidence of a causal link between a trace amount of methamphetamine found in his urine and the car accident and whether the appellate court erred in holding that the state proved that he was guilty of misdemeanor DUI. The court reversed the appellate court's judgment and held that the state satisfied its burden of proof of misdemeanor DUI where, although the evidence did not establish exactly when defendant last used methamphetamine, a rational jury could have found that his last use was sufficiently recent that some remnants of the drug remained in his urine on the night of the accident. The court also held that defendant's driving was a proximate cause of the victims' death and therefore, defendant was guilty of aggravated DUI.