State v. HasteyAnnotate this Case
At issue was whether evidence of the factual circumstances underpinning Defendant’s prior manslaughter conviction was admissible to establish an enhancing factor necessary to convict Defendant of the Class B offense of operating a motor vehicle while under the influence of intoxicants (OUI).
Defendant was indicted for aggravated criminal OUI. The indictment alleged that the enhancing factor was Defendant’s 1991 manslaughter conviction that involved the operation of a vehicle while under the influence of intoxicants. The Supreme Judicial Court vacated the order of the unified criminal docket granting Defendant’s motion in limine to exclude evidence of his alleged intoxication at the time he committed his manslaughter offense. The Court held that the trial court erred when it ruled that the State’s proof regarding Defendant’s prior conviction was limited to the face of the prior indictment and judgment and commitment, which did not establish that Defendant was operating while under the influence at the time of the homicide. The Court then vacated the order granting the motion in limine and remanded for entry of an order denying the motion.