Owens v. State
Court of Special Appeals of Maryland
611 A.2d 1043 (1992)
Responding to a complaint about a suspicious truck, an officer found Owens (defendant) asleep at the wheel of a parked truck in a private driveway, engine running and lights on, with an open beer can between his legs and two empty cans in the backseat; sobriety tests confirmed intoxication, and Owens was charged with driving drunk on a public highway. Owens did not dispute being drunk in the parked truck but argued insufficient evidence showed he had actually driven while drunk on a public road, and the trial court found him guilty based on circumstantial evidence.
Whether circumstantial evidence alone — an intoxicated defendant found asleep in a running, parked vehicle with evidence of recent drinking, following a complaint about the vehicle's suspicious presence — is legally sufficient to convict him of drunk driving on a public highway.