## Facts

- Corey Adam Hutchins drove a 1999 Dodge Stratus and turned left in front of an oncoming vehicle on a clear, flat, sunny afternoon, causing a serious collision; his three young daughters were passengers.
- The other driver was traveling about 45 mph (the posted limit); airbags deployed and the other vehicle was totaled.
- A responding trooper smelled marijuana while searching Hutchins’s vehicle for documents and found marijuana in a Camel cigarette case in the driver’s door pocket.
- Hutchins admitted the crash was his fault and admitted smoking marijuana earlier that day; he denied alcohol use.
- A trooper observed signs consistent with marijuana impairment, including abnormal pupils, fatigue, and difficulty concentrating, and described Hutchins as unusually calm despite his children’s injuries.
- Field sobriety testing occurred at the hospital; Hutchins was arrested and consented to a blood test.
- Toxicology showed no alcohol and 43 ng/ml of carboxy-THC (a marijuana metabolite); about 0.63 grams of marijuana was found in the vehicle.
- No expert testified to correlate the metabolite level to impairment at the time of driving.

## Issues

1. Whether the evidence was sufficient to prove Hutchins drove under the influence of a controlled substance to a degree that impaired his ability to safely drive.
2. Whether the evidence was sufficient to sustain the REAP convictions arising from the same driving conduct.
3. Whether expert testimony was required to link the marijuana metabolite finding and admitted marijuana use to impairment.

## Decision

- The Superior Court affirmed the DUI-controlled-substance impairment conviction based on the totality of the circumstances.
- The court held that the Commonwealth did not need expert testimony on the metabolite level where impairment was supported by driving behavior, physical evidence, and lay observations.
- The court reversed in part on the REAP counts and remanded for resentencing.

## Legal Principles

- Drug-DUI impairment (impairment of the ability to safely drive) is evaluated under the totality of the circumstances, not by any single factor such as toxicology.
- An admission of earlier marijuana use and a metabolite reading, standing alone, may be insufficient to prove impairment; expert testimony may be necessary if the Commonwealth relies solely on toxicology/usage timing.
- Where there is independent, non-expert evidence of impairment (e.g., unexplained dangerous driving under normal conditions plus corroborating observations and physical evidence), expert testimony is not categorically required.
- Sufficiency review considers the evidence in the light most favorable to the Commonwealth as verdict winner and asks whether a fact-finder could find each element beyond a reasonable doubt.

## Conclusion

The court upheld a marijuana-based DUI impairment conviction because the crash circumstances, marijuana evidence, admissions, and officer observations together permitted an inference of impaired driving without expert toxicology interpretation, but it reversed part of the REAP disposition and remanded for resentencing.


Commonwealth v. Hutchins, 42 A.3d 302 (Pa. Super. Ct. 2012)