Owens v. State

93 Md. App. 162, 611 A.2d 1043 (1992)



A conviction upon circumstantial evidence alone is not to be sustained unless the circumstances are inconsistent with any reasonable hypothesis of innocence.


The police officer responded to a complaint of a suspicious car and found defendant sleeping in his car in a driveway with the motor running. The police awoke defendant, who was confused and disoriented. Defendant had an open can of beer between his legs and empty cans in the car. Defendant smelled of alcohol and his driver's license revealed an alcohol restriction. Defendant was eventually convicted of driving while intoxicated. On review, defendant argued that there was insufficient evidence to convict him because the State of Maryland failed to establish whether defendant was coming or going from the driveway. 


Is circumstantial evidence alone legally sufficient to prove guilt at trial?




The court found that the case was based entirely on circumstantial evidence. Furthermore, the court found that the fact that defendant was in a car with beer cans indicated that he was leaving the driveway. Also, the court concluded that the police would not have been contacted if defendant had just entered the car in the driveway. Thus, it was more likely that he had been observed driving in the neighborhood. Defendant's conviction was affirmed.

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