Background
Emergency responders found Michael Layaw unconscious in the driver’s seat of his vehicle, which was stopped at a traffic light in a lane of traffic in Manchester, Connecticut. He displayed signs of an opioid overdose and improved after Narcan was administered.
At the hospital, Layaw reported that he had been driving when he sniffed heroin. He later told an officer that he had snorted heroin while stopped at the red light and, after learning police would seek an arrest warrant, said he had not been driving. A jury convicted him of operating a motor vehicle while under the influence of drugs under General Statutes § 14-227a (a)(1).
The Court’s Holding
The Connecticut Appellate Court affirmed. It held that the evidence was sufficient for the jury to find beyond a reasonable doubt that Layaw operated his vehicle while impaired by drugs.
The jury could credit Layaw’s hospital-record admission that he sniffed heroin while driving, rather than his later account that he used the drug only after stopping. That admission, combined with the fact that he was found unconscious in the driver’s seat of a vehicle stopped at a traffic light in an active traffic lane, supported a reasonable inference that he had operated the vehicle while impaired.
Key Takeaways
- Operation under Connecticut’s impaired-driving statute may be proved through circumstantial evidence.
- A jury may credit an earlier admission over a defendant’s later, self-serving explanation.
- The absence of direct evidence about a running engine or keys in the ignition does not preclude a finding of operation.
Why It Matters
The decision reinforces that Connecticut’s drugged-driving statute reaches more than observed driving. Where the surrounding facts and a defendant’s admissions reasonably show impaired operation, a conviction may stand even without an eyewitness to the vehicle in motion or proof that the engine was running when responders arrived.