Case Brief Assignment
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Law
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Apr 29, 2024
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Case Brief Assignment
Angelica Simmons
Criminal Justice, Liberty University
CJUS230- Criminal Justice Research and Writing
Professor, Zuidema
December 10
th
, 2023
CJUS230 Case Brief
Caption
Lambert v. Commonwealth, 274 Va. 630 (2007)
Facts
During the unfortunate incident that occurred on March 1, 2015, Clinard Gary Lambert found himself in a collision with Donna Turner’s car, tragically resulting in the loss of passenger Forrest Ramey’s life. Following this devastating event, Lambert faced serious charges including aggravated involuntary manslaughter and driving under the influence. Multiple witnesses were present during the accident and attested to observing signs of impairment from Lambert before and after impact. To gather more evidence regarding his condition at the time of the incident, a subsequent blood test was conducted which revealed traces of methadone as well as medications such as Valium and Xanax. Initially denying any drug consumption involvement altogether, Lambert later confessed to undergoing methadone treatment.
Procedural History
Lamberts’s case was brought before to the Court of Appeal. His argument centered on questioning the adequacy of conclusive proof regarding self-administration. Regrettably, his plea
was dismissed by the trial court, leading to Lambert’s conviction for both charges being upheld. The Court of Appeals subsequently affirmed these convictions as well, compelling Lambert to seek redress from Virginia’s Supreme Court in hopes of obtaining a thorough reevaluation and deliberation of his case.
Issue
Commonwealth did not present enough evidence to the jury verdicts to support that Lambert had self-administered intoxicants that impaired his ability to drive safely. Commonwealth had police statements and evidence from the crash to present but did not have enough prior to in incident to prove that Lambert administered the drugs himself.
Rule of Law
Code § 18.2-266 shall be unlawful for any person to drive or operate any motor vehicle . . . (iii) while such person is under the influence of any narcotic drug or any other self-administered intoxicant or drug of whatsoever nature, or any combination of such drugs, to a degree which impairs his ability to drive or operate any motor vehicle and Code § 18.2-36.1(A) is any person who, as a result is caught driving under the influence and establishes involuntary manslaughter shall be guilty.
Holding
The court presented the evidence before the jury, and the inferences reasonably deducible from the most favorable to the Commonwealth. The evidence that was presented concerned the presence of intoxicants in Lambert’s blood which were sufficient to impair his ability to drive safely. During the Court of Appeals, the methadone treatment clinic was a part of a voluntary program and Lambert agreed to ingest methadone. At that time there was no evidence as to how the other drugs got into Lambert’s blood.
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Rationale
The court applied the standard in reviewing the evidence with the light most favorable to the Commonwealth. Lambert’s initial denial to subsequent in administering to the methadone treatment, and the significant drug levels that were found in his blood that formed a basis for self-administration. The Court distinguished Lambert v. Commonwealth, finding it inapplicable of the evidence. The conviction was affirmed, while being upheld in the trial court and The Court
of Appeal’s determinations.