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John Austin v. State

Facts:

Defendant was charged with DUI and driving while intoxicated after a police officer saw her driving on a public road and noticed that her speech was slurred, her eyes were watery and bloodshot, and there was a strong odor of alcohol on her breath. The officer testified that he conducted three field sobriety tests, the nystagmus test, the walk and turn, and the one-leg stand, and that defendant failed all three tests. However, the officer did not take a sample of defendant’s breath or blood for analysis. He also testified that defendant was very loud and obnoxious while he was booking her at the police station and that she injured herself after she was placed in a cell. In her defense, defendant claimed that she suffered post-traumatic stress disorder and offered the testimony of a psychiatrist to explain her behavior. However, the trial court ruled that the psychiatrist’s testimony was not admissible. Defendant was convicted of driving under the influence (DUI) after a jury trial in the Circuit Court for Howard County (Maryland), and she appealed.

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Issue:

• Whether the psychiatrist’s testimony was admissible in DUI proceedings?

Discussion:

The appellate court held that the trial court abused its discretion by allowing the State to offer evidence detailing defendant’s post-arrest behavior to raise an inference that she was intoxicated and then excluding expert testimony defendant offered to explain that behavior. The appellate court vacated the trial court’s judgment and remanded the case for a new trial

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Disclaimer:

These summaries are provided by the SRIS Law Group. They represent the firm’s unofficial views of the Justices’ opinions. The original opinions should be consulted for their authoritative content.