Clinard Gary Lambert v. Commonwealth of Virginia (2020) – Legal Case Brief

Facts

Gary Lambert, the defendant was driving a truck that was involved in an accident with Donna Turner who was driving a Chevrolet Cavalier on March 1, 2015, causing the death of Forrest Ramey. Lambert’s truck crossed the centerline from westbound and entered the eastbound corroding with his left guardrail. Lambert scraped for at least forty feet along the guardrail, before stopping. Turner was driving on the same road eastbound approaching in opposite direction, coming around a curve. Although she saw a truck ahead was unable to evade a collision. Turner’s passenger sustained blunt force injuries which resulted in his death. Gary Lambert sustain head injuries, had slurred speech, seemed sleepy, and was getting support from the guardrail after evacuation. A blood test revealed the presence of a high level of methadone, Xanax, and Valium in his blood, during the accident.

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Procedural History

Lambert’s case was initially presented before the Circuit Court of Russell County where the defendant was charged with driving under intoxication and aggravated involuntary manslaughter. The defendant was found guilty of the two charges by the jury and was sentenced to seven years in prison and a $1500 fine. The convictions were appealed to the Court of Appeals in Virginia which considered and granted his assignment error in 2019, but the convictions were affirmed.

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Issue

Analysis of Lambert’s blood samples extracted at the accident site revealed that he was driving while intoxicated by narcotic drugs. The blood test revealed the presence of a high level of methadone, Xanax, and Valium in his blood which could have impaired his ability to drive safely.  The case’s main issue is whether the drugs found in Lambert’s blood system were self-administered.  

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Rule of Law

Based on Code § 18.2-266 it is illegal for any individual to operate or drive any motor vehicle while under the influence of a narcotic drug or other self-administered drugs or intoxicant of any nature, or a combination of any such drugs to a level that impairs individual ability to safely operate or drive any motor vehicle.

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Holding

Yes. The evidence presented to the jury and the inferences rationally deducible therefrom were enough to support the results beyond reasonable doubt that the accused had before the accident self-administered drugs that damaged his aptitude to drive safely. The holding affirmed the court of appeals ruling.

Rationale

The evidence regarding intoxicants’ presence in the blood of the accused was enough to impair his aptitude to drive safely was obvious. When asked separately by Trooper Osborne and Nurse Morrison whether he had taken any alcohol or drugs, he initially denied the claim. Later confessed to Trooper that he was at a methadone treatment clinic where he received methadone. Lying initially and denial of being under the influence of drugs demonstrated an act of consciousness of guilt and the intention to conceal his responsibility for the act. The trial court judged, and the Court of Appeals supported that the methadone treatment clinic is a voluntary program and that the accused had voluntarily agreed to take methadone during the program participation. Also, there was no evidence of where the accused had gotten the other two drugs that showed in his blood system. The accused was aware that he was on drugs that were likely to affect his mental stability but still engaged in unsafe driving.

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