ANGELA CARMEN BROWN, APPELLANT,
v.
STATE OF FLORIDA, APPELLEE
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Angela Brown was convicted of driving under the influence with property damage after a multi-car collision. The appellate court reversed her conviction on the DUI property damage charge because the State failed to present evidence proving the damaged truck belonged to someone other than Brown, an essential element of the offense.
The trial court erred in denying the motion for judgment of acquittal because the State failed to prove an essential element of the offense—that the damaged property belonged to someone other than the defendant. Without such evidence, no rational trier of fact could find the State had proven the charged offense.
[1] A conviction for driving under the influence with damage to the property of another requires proof that the damaged property belonged to someone other than the defendant.
[2] A trial court errs in denying a motion for judgment of acquittal when the State fails to present evidence of an essential element of the charged offense.
Previewing 2 of 4 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“Subsection (3)(c)(l) requires the State to prove that the damaged property belonged to someone other than the defendant. But the State provided no evidence that someone other than Ms. Brown owned the 1997 Chevy truck.”
Establishes the missing element necessary for conviction and explains why the State failed to prove its case.
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Join FLexlaw to unlock all legal intelligenceAngela Carmen Brown was involved in a multi-car collision and was charged with several offenses including driving under the influence with damage to t…
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The State charged Angela Carmen Brown with several offenses related to a multi-car collision. Among them was driving under the influence with damage to the property of another, specifically, a 1997 Chevy truck that Ms. Brown was driving. But the State did not produce any evidence of the truck’s ownership. Ms. Brown moved for a judgment of acquittal *780on this basis, which was denied. The jury subsequently found her guilty. Ms. Brown appealed. Because the State did not prove the existence of the charged offense, we conclude that the trial court erred in denying the motion for judgment of acquittal on this charge and reverse.
“In reviewing a motion for judgment of acquittal, a de novo standard of review applies.” Pagan v. State, 830 So.2d 792, 803 (Fla.2002) (citing Tibbs v. State, 397 So.2d 1120 (Fla.1981)). “If, after viewing the evidence in the light most favorable to the State, a rational trier of fact could find the existence of the elements of the crime beyond a reasonable doubt, sufficient evidence exists to sustain a conviction.” Pagan, 830 So.2d at 803 (citing Banks v. State, 732 So.2d 1065 (Fla.1999)).
To determine whether the State presented sufficient evidence for the jury to find that Ms. Brown was driving under the influence with damage to the property of another, we review the statute defining the offense:
(3) Any person:
(a) Who is in violation of subsection (1) [by driving or being in actual physical control of a vehicle while under the influence of drugs or alcohol to a certain degree];
(b) Who operates a vehicle; and
(c) Who, by reason of such operation, causes or contributes to causing:
1. Damage to the property or person of another commits a misdemeanor of the first degree, punishable as provided in s. 775.082 or s. 775.083.
§ 316.193(3), Fla. Stat. (2007).
Subsection (3)(c)(l) requires the State to prove that the damaged property belonged to someone other than the defendant. But the State provided no evidence that someone other than Ms. Brown owned the 1997 Chevy truck. Without evidence of this element, no rational trier of fact could have found that the State had proven the existence of the charged offense. Because the trial court should have granted the motion for judgment of acquittal, we reverse and remand for the trial court to vacate the conviction and sentence for driving under the influence with damage to the 1997 Chevy truck. We affirm Ms. Brown’s other convictions and sentences without comment.
Affirmed in part, reversed in part, and remanded.
DAVIS and LaROSE, JJ„ Concur.
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Citator
Authorities Cited
- Pagan v. State, 830 So. 2d 792 (Fla. 2002)
- Delbert Lee Tibbs v. State, 397 So. 2d 1120 (Fla. 1981)
- Donald B. Banks v. State, 732 So. 2d 1065 (Fla. 1999)