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When a person is arrested for DUI, his driver's license is confiscated by the arresting officer and he is given a notice of "administrative suspension". He is also given a citation to appear in court to face criminal drunk driving charges.

These are usually two very different procedures: (1) the administrative suspension for driving with blood-alcohol of .08%, is administered in most states by its department of motor vehicles, and (2) the criminal prosecution for the two separate offenses of driving under the influence of alcohol (DUI, DWI or OUI) and driving with .08%,  which takes place in the courts.

In other words, even though he only committed the act of driving once, the individual is being prosecuted in court for two different crimes: DUI and driving with a .08% BAC. He can even be convicted of both offenses (although he can only be punished for one). How is this possible?

It gets worse…

The driver has already been punished by one state agency (the Department of Motor Vehicles) for driving over .08% by having his license suspended. If he is prosecuted and convicted by another agency in the state's criminal court of driving over .08% (and/or driving under the influence), he will be punished once again. The sentence may involve jail, fines, DUI schools, community work, probation, ignition interlock devices — and a restricted, suspended or revoked license.

How many times can the state prosecute a person for a single crime?

Our Constitution says only once. The Fifth Amendment specifically provides that no person shall "be subject for the same offense to be twice put in jeopardy of life and limb". So is this another example of "The DUI exception to the Constitution?

Let's first take the question of charging defendants with both DUI and .08%….

The courts in the different states wrestled with this one for awhile, but eventually came to the conclusion that the driver actually commited two different crimes. As an Indiana court reasoned, "the test to be applied to determine whether there are two different offenses or only one, is whether each provision requires proof of a fact which the other does not."  Sering v. State, 488 N.E.2d 369 (1986). The .08 statute required proof of blood-alcohol concentration; although blood-alcohol evidence was used to prove the DUI crime as well (a person is usually presumed to be under the influence if his BAC is .08% or higher), the offense could be proved without it. So it's ok to prosecute and convict him for both crimes — so long as you don't punish him for both. 

Hmmm…

Well, what about punishing the driver by suspending his license when he's arrested — and then punishing him again in court? In fact, punishing him in court with a sentence that in some states may include another license suspension?

This one caused the judges a bit more trouble. This wasn't a case where the person was committing two arguably different crimes: he was being punished by two different state agencies for the same crime: driving with .08% BAC. But there had to be some way to get around the Constitution…

The courts could not agree. Some said that there was no double jeopardy or double punishment since the DMV license foreiture was not really a "punishment"  but only a "civil sanction". Others took the position that this was, in fact, a violation of the Fifth Amendment, and they relied upon a 1989 U.S. Supreme Court decision (U.S. v. Halper, 490 U.S. 435) which involved civil forfeitures and criminal punishments for selling marijuana. In that case the Court held that a "civil sanction" was actually a punishment — and thus double jeopardy — if (1) the "clear focus of (the statute) is on the culpability of the individual", and (2) the legislature "understood these provisions as serving to deter and punish". The Court added that "the historical understanding of forfeiture as punishment" weighs heavily in favor of the conclusion that forfeiture continues to serve punitive purposes.

Well, relying upon the Supreme Court's ruling, an alarming number of courts around the country were throwing out criminal DUI charges on double jeopardy grounds. This, of course, infuriated MADD, legislators, prosecutors, law enforcement, insurance companies and pretty much everyone else who did not take the Constitution too seriously. But rescue arrived  from a later, more conservative U.S. Supreme Court.

In 1997, Chief Justice Rehnquist revisited the forfeiture-punishment problem and did something that is rarely ever done: he criticized and flatly rejected the earlier Supreme Court's ruling: "We believe that Halper's deviation from long-standing double jeopardy principles was ill-considered.  Halper's test for determining whether a particular sanction is "punitive", and thus subject to the strictures of the Double Jeopardy Clause, has proved unworkable. Hudson v. U.S., 592 U.S. 93 (1997).

Since then, the courts have had little trouble finding that a police officer who confiscates and suspends the driver's license of a drunk driving suspect is merely administering a "civil sanction", not "punishment", and that when he is later convicted in court and is fined, jailed and has his license suspended again, well that'ss not really double jeopardy or multiple punishment. It just looks an awful lot like it.

From Lewis Carroll's Through the Looking Glass:

"When I use a word," Humpty Dumpty said, in a rather scornful tone, "it means just what I choose it to mean, neither more nor less".

"The question is," said Alice, "whether you can make words mean so many different things".

"The question is," said Humpty Dumpty, "which is to be master, that's all".
 

DUI BLOG

The single most important factor in whether an individual will be arrested for driving under the influence (DUI) is not the evidence. It is the individual human differences of the officer himself.

A study by the National Highway Traffic and Safety Administration [U.S. Department of Transportation Report No. H5-801-230] points out the effect of these differences on an officers' observations and conduct in the field:

The officer's age and experience play a role in his alcohol-related arrest decisions. Younger officers, and those with relatively few years of seniority, tend to have a more positive attitude toward alcohol-related enforcement and make more arrests on that charge than do older officers. This result was found to hold true regardless of the type of department in which the officer serves or the specific type of duty to which he is assigned.

The officer's personal use of alcohol is inversely related to his level of alcohol-related enforcement. Patrolmen who drink make significantly fewer arrests than those who do not, and those who drink frequently make significantly fewer arrests than those who use alcohol only occasionally.

Lack of knowledge concerning the relationship between alcohol and intoxication is widespread among police officers and imparts a negative influence on alcohol-related enforcement. Most officers underestimate — often by a wide margin — the amount of alcohol a suspect would have to consume in order to achieve the statutory limit of blood-alcohol concentration.

Specialized training has a strong positive influence on alcohol-related arrests. Patrolmen who have received instruction in the operation of breath testing devices and/or in alcohol-related enforcement (particularly in municipal departments) were found to lack this specialized training.

Specialization in duty assignment can also enhance alcohol-related enforcement. Patrolmen assigned to traffic divisions, in particular, produce higher arrest rates than those charged with general patrol duties.

Near the end of the duty shift, alcohol-related investigations decrease substantially. This is particularly true in departments that have adopted relatively time-consuming procedures for processing alcohol-related arrests.

Weather conditions also affect alcohol-related arrests. There is encouraging evidence that foul weather has a positive influence on the attitude of many officers; they are more appreciative of the risk posed by an alcohol-related suspect when driving conditions are hazardous, and are less likely to avoid the arrest when those conditions prevail.

The suspect's attitude can have a strong influence on the arrest/no arrest decision. If the suspect proves uncooperative or argumentative, a positive influence for arrest results. Conversely, the likelihood of arrest decreases when the suspect seems cooperative.

The suspect's race is a key distinguishing characteristic in alcohol-related cases. The officers surveyed (the overwhelming majority of whom were white) reported releasing significantly more nonwhite suspects than they arrested. The data do not suggest that this reflects a greater tendency to exercise discretion when dealing with nonwhite drivers. Rather, the officers seem more willing to initiate an investigation when the suspect is not of their own race.

A suspect's age is another distinguishing characteristic of these cases, and patrolmen reported releasing significantly more young suspects than they arrested. This appears to stem from two distinct causes. First, young officers exhibit more sympathy for young suspects, i.e., seem less disposed to arrest a driver of their own age group. Second, older officers seem more willing to stop young suspects, i.e., are more likely to conduct an investigation when the driver is young, even if the evidence of alcohol-related violation is not clear.

The suspect's sex also plays a role in the arrest/no arrest decision. Patrolmen seem more reluctant to arrest a woman for alcohol-related violations, largely because processing of a female arrestee is generally more complex and time consuming.

Most DUI cases depend largely upon two variables: the officer and the machine. As has been discussed repeatedly in past posts, the machine is an unknown and unreliable variable. As this federal study indicates, so is the officer.
 

DUI BLOG

Because of their unpopularity, drunk driving cases are often used by police and prosecutors to chip away at the constitutional guarantees of our citizens.  See The DUI Exception to the Constitution.   Every once in awhile, however, the media shows a little courage and gets it right.  From an editorial in yesterday's New York Times:

Is the Driver Drunk?

Jan. 5.  New York, NY - The Fourth Amendment prohibits the police from searching individuals without a warrant, but the Supreme Court allows exceptions to that rule for “exigent circumstances” — when the police believe that the delay involved in getting a warrant would lead to destruction of evidence.

In Missouri v. McNeely, scheduled for argument at the court on Wednesday, the police forced a driver to take a blood test at a hospital without a warrant, after he refused to take a breath test with a portable machine when he was stopped for erratic driving. The blood test showed that his blood alcohol content was 0.154 percent, or almost twice the state’s legal limit.

The Missouri Supreme Court wisely ruled that the warrantless blood test was an unreasonable search because there was no emergency that prevented the police from getting a search warrant in a timely manner before the alcohol in the driver’s blood dissipated.

Missouri is now asking the United States Supreme Court to overturn the state court ruling and to radically revise Fourth Amendment law so that police — without a warrant — can draw blood from every person arrested on suspicion of drunken driving, regardless of the circumstances. The United States government, siding with Missouri, argues that warrantless blood draws are needed “to prevent the imminent destruction of evidence.”

But in 21 states, including Missouri, the police have successfully obtained thousands of warrants to get blood alcohol evidence.

If the Supreme Court applies the blanket rule Missouri seeks, it will diminish constitutional rights without increasing public safety in any meaningful way.

DUI BLOG

Four days ago I posted about a case, Missouri v. McNeely, that was to be argued to the United States Supreme Court.  See The Slow Death of the 4th Amendment in DUI Cases.  The case involved the forceful use of hypodermic needles on drunk driving suspects.  Following are comments from the Washington Post on the arguments yesterday and the justice's questions which may provide a window into this important issue:

Supreme Court Seems Unlikely to Let Police Order Blood Tests for  Drunk Driving Suspects

Washington, DC – Jan. 9 — The Supreme Court on Wednesday seemed unlikely to allow police to routinely force suspected drunk drivers to give a blood sample without the officers at least trying to obtain a warrant from a judge.

There seemed to be little, if any, support for the proposition that the usual constitutional protections that require a warrant for searches do not apply in drunk-driving arrests. Missouri, backed by the Obama administration, argued that a suspect’s dissipating blood-alcohol content meant that, in effect, evidence was being lost and thus drawing blood should not require consent or a judge’s order.

That argument drew fire almost immediately.

“How can it be reasonable to forgo the Fourth Amendment in a procedure as intrusive as a needle going into someone’s body?” Justice Sonia Sotomayor asked. The justice, interestingly, is a diabetic who has given herself daily shots of insulin since childhood.

Justice Antonin Scalia immediately signaled that he considers a blood test different from other procedures the government may require.

“Why don’t you force him to take the breathalyzer test, instead of forcing him to have a needle shoved . . . in his arm?” Scalia asked John N. Koester Jr., the Missouri prosecutor presenting the case for his state. Koester replied that a breathalyzer requires the suspect’s participation.

For most of the hour-long argument, the justices seemed to be debating among themselves what emergency circumstances — an inability to contact a magistrate late at night, for instance — might allow taking blood from an uncooperative suspect…

Courts nationwide are divided about whether a 1966 Supreme Court ruling created an emergency exception to the warrant requirement for taking blood or whether ”special facts” must be present to make a warrant unnecessary.

Koester and Assistant Solicitor General Nicole A. Saharsky argued that the rapid dissipation of alcohol was enough to relieve law enforcement from the warrant requirement.

“The police are facing a destruction of critical blood-alcohol evidence,” Saharsky told the court. “Every minute counts, and it’s reasonable for the officers to proceed.”

But Justice Ruth Bader Ginsburg said that it is relatively easy and quick for police to get a warrant — a phone call is often enough — and that police could attempt to secure one in the time it takes to drive a suspect to a hospital for the procedure. If 30 minutes passes without an answer, perhaps the officer could proceed, she suggested.

Steven R. Shapiro, legal director of the American Civil Liberties Union, represented McNeely and told the court that Missouri, the states supporting it and the U.S. government are asking for too much.

“The issue in this case is whether the state may stick a needle in the arm of everyone arrested on suspicion of drunk driving without a warrant and without consent,” Shapiro said.

He has noted that states may revoke a driver’s license for a suspect who refuses to take a test, so there is an incentive to agree. Shapiro said half of the states — Maryland and Virginia as well as the District of Columbia are not among them — prohibit blood draws without warrants…

For a clearer picture of what we're talking about, see my posts Forced Blood Draws by Cops in Back Seat, Suspect Resisting Forced Blood Draw is Tasered, Dies and Catheter Forced Up Penis After DUI Arrest.
 

DUI BLOG

Many people suspected of alleged crimes across North Carolina have had the suspicion hanging over their heads for, in some cases, more than a year to delays in the North Carolina State Crime Laboratory. Some cases involving driving while impaired allegations are included in the lengthy delays in cases where the crime lab is asked to perform toxicology testing on a blood sample.

WNCT-TV News in Greenville, North Carolina, reports that the crime lab has less staff than in previous years to process evidence, leading to long delays for defendants in their criminal cases. Directors who run the crime lab also say that an increase in evidence requests has added to delays in processing.

In some areas of North Carolina, prosecutors have had difficulty in getting former analysts from the crime lab into court to testify in North Carolina DWI cases, forcing the prosecutor to dismiss the DWI case, according to WNCT. In many cases, prosecutors seek a continuance, and delay the criminal proceedings for a longer period of time.

A defendant accused of a crime has the right to confront the witnesses against her or him. That constitutional right was addressed by the United States Supreme Court in 2009. The individual crime lab analyst who performs toxicology tests cannot be replaced by a different analyst who may understand toxicology testing to support a crime lab test analysis, if a criminal defendant asserts her or his right to confront the witnesses against the defendant.

Sources say that a laboratory in Asheville could possibly handle blood testing in DWI cases. WRAL-TV reports that the added lab for blood testing could reduce some backlog in processing evidence in criminal cases. The station also says that a district attorney says that Wake County is planning to open its own crime lab next month.

Sources:

• 9 on Your Side WNCT-TV, “Crime lab cutbacks lead to long NC court wait,” Aug. 20, 2012
• WRAL-TV, “NC crime lab has less staff, money but more work,” updated Aug. 20, 2012

Greenville DUI Attorney Blog | North Carolina Underage Drinking Lawyer | Pitt County First DUI Law Firm

I’ve written in the past about the guilty-until-proven-innocent approach to DUI license suspensions and the almost complete lack of due process.  See, for example, "Due Process" for DUI License Suspensions, Secret Memo: DMV License Suspension Hearings Rigged and Judge: DUI License Suspension Hearings "Unacceptable".      

In California, for example, when a citizen is suspected of drunk driving and is arrested, the cop confiscates the license and gives the suspect a "Notice of Suspension".  The citizen has 10 days in which to call the DMV to demand a hearing, or the right to contest the cop’s automatic suspension is lost.  If a hearing is granted, it will be at the DMV’s offices; the prosecutor will be a DMV employee with a high school degree.  Oh yes, and the judge will be….the same person.  Right: judge, jury and executioner — without any legal training and answerable only to his/her employer — the DMV.

As bad as this is, apparently our northern neighbors in the province of Alberta have gone a step further:  unlike DUI suspensions in the U.S., which are for a specific period of time, those in Alberta are for an indefinite period — until the criminal charges are "resolved" in court.  In other words, the accused — guilty or innocent — is coerced into pleading guilty if he wants his license back.

Lawyers Call Alberta’s Drunk Driving Penalties Unconstitutional

Edmonton, Alberta, Canada.  June 19 – Civil Liberties Association lawyer Joseph Arvay has been retained by Alberta firm Roadlawyers, which specializes in drunk driving cases, one of several that are decrying the Alberta government’s decision to indefinitely suspend licences of drivers who blow over the Criminal Code limit of .08 blood-alcohol content.

Drivers police deem are over the .08 limit will immediately have their licences suspended without even seeing a judge, a penalty that will remain in place until the charge is resolved in court.

“I think it’s clearly contrary to the Constitution and clearly contrary to the Charter (of Rights and Freedoms),” said Roadlaywer attorney Tim Foster.

“We intend to challenge the legislation as soon as we get retained on a file dealing with one of these — we’re going to bring a Constitutional challenge to try to strike the law down.”…

In what’s being called a first for Canada, Transportation Minister Ric McIver came out Monday saying drivers who blow over .08 will be hit hard with an indefinite suspension starting July 1, one of several get-tough measures rolled out in the Traffic Safety Amendment Act passed last year.

McIver said drivers simply weren’t refraining enough from tipping their glasses before hitting the roads and harsher penalties were needed to ensure “all of us feel more secure when we go out on Alberta roadways.”

Many lawyers, however, say the new penalties are nothing more than a tactic that will strong-arm drivers into issuing guilty pleas rather than challenge their cases in court.

“There’s some good and bad about that from a public policy perspective,” said Alan Pearse, who specializes in DUI cases in Calgary.

“The good news is you will almost certainly force guilty people to plead guilty. The bad news is you’re likely going to force some innocent people to plead guilty as well.”

Lawyer Bob Sawers called it the government’s way to “extort” guilty pleas from Albertans who can’t afford to lose their licences for several months and said he would demanding trial dates be set within two months.

Apparently, Transportation Minister McIver’s idea that "harsher penalties were needed to ensure all of us feel more secure" is to simply force anyone suspected of drunk driving to plead guilty.


I can imagine prosecutors, cops and Mothers Against Drunk Driving drooling over the idea of adopting this approach in the States….
 

DUI BLOG

I’ve posted long and hard over the years about the inaccuracy and unreliability of breathalyzers.  See How Breathalyzers Work – and Why They Don’t.  But at least you could always refuse to take the test.  You aren’t required to incriminate yourself, right?  I mean, this is America and we have the Constitution to protect us.

Maybe not.  This looks like yet another in a long list of constitutional rights that are slowly disappearing in DUI cases.  See, for example, The DUI Exception to the Constitution, The Disappearing Right to Jury Trial…in DUI Cases, DUI and the Disappearing Right to Counsel, Are DUI Roadblocks Constitutional? and Forced Blood Draws by Cops: Constitutional?.

House Votes to Criminalize DUI Test Refusals

Topeka, KS.  May 17 —  After a lengthy discussion of constitutional rights, the House has approved a bill that makes it a crime for suspected repeat offenders to refuse a drunk-driving test…

Under Senate Bill 60, drivers with a DUI conviction or prior refusal of a DUI test would automatically be guilty of a misdemeanor if they refuse a test. The penalty would be the same as for a DUI conviction.

The House passed the bill 103-13, but not without some concerns expressed by members that it “tramples” the right to remain silent when accused of a crime.

Rep. Sean Gatewood, D-Topeka, said he’s seen many drunk driving crashes and the harm they cause working as a firefighter and paramedic.

But he said he was not comfortable with making it a crime to refuse to take a breath or blood test.

“These are American citizens and they have the right to remain silent, which this bill sort of tramples on, because if you just stand there silent … then you’re a criminal,” Gatewood said. “You have your 4th and 5th Amendment rights … and I just think there is no greater ridge to stand on than the Constitution of the United States.”

Gatewood proposed to send the measure back to a House-Senate conference committee for further work, but that motion died on a 23-88 vote.

Rep. Pat Colloton, R-Leawood, who carried the bill on the floor, acknowledged that its impact on constitutional rights was an important issue, but on balance she supported it.

She said courts are being clogged with repeat offenders who refuse the DUI test and take their chances with a jury.

Some lawmakers said stopping drunk drivers outweighed the constitutional questions.

“I would gladly walk the line, breathe into the tube and draw my blood if it would get repeat drunk drivers off the road,” said Rep. Bill Otto, R-LeRoy. “This is about people who are killing people.”

“This is not about constitutional rights,” he continued. “What about the constitutional right to life, liberty and the pursuit of happiness? (a phrase from the Declaration of Independence, not the Constitution) When you’re killed by a drunk driver, they’ve deprived you of your life. Death penalty, when you did nothing wrong.”

So….if you refused to incriminate yourself, you would be convicted of a crime and given the same sentence as if you had been convicted of drunk driving.  In other words, you are basically convicted of drunk driving because you wouldn’t incriminate yourself!

Another constitutional right slowly fades away….
 

DUI BLOG

A North Carolina state highway trooper reportedly did not appear in court Monday. The court calendar apparently included at least 20 cases involving allegations of driving while impaired where the trooper was the arresting officer. In all, as many as 90 misdemeanor traffic charges were scheduled for hearing and in the absence of the state’s star witness, the Montgomery County judge presiding over the court calendar reportedly dismissed the charges.

It is unclear from news reports at what stage the court cases had reached before the trooper failed to appear in court Monday. The District Attorney’s Office apparently refused to indicate whether or not prosecutors will seek to pursue any of the cases, including the 20 or so cases involving DWI charges. It is equally unclear from the media whether the prosecutor or the judge initiated the dismissals.

The state trooper who had ticketed the defendants who had court appearances Monday is also a Candor town commissioner. He has been under fire after his own arrest on serious allegations that he unlawfully accessed a government computer. Some people apparently are speculating that the town commissioner’s legal difficulties may be one explanation for his failure to appear as a state trooper to support the prosecutor’s misdemeanor cases in criminal court.

It may be possible that many of the 90 dismissed cases, including the DWI charges, could be brought back into court for prosecution. In the meantime, those who had been charged with the variety of crimes may be in legal limbo as prosecutors decide how to proceed.

Greenville DWI defense lawyers understand that many people can be confused by many aspects of the complex rules of court in North Carolina. Often, in misdemeanor cases especially, many people in Pitt County and other areas of North Carolina are tempted to just pay the ticket or plead guilty in court to get the matter behind them.

It is important to discuss an individual case to consider speaking with an experienced criminal defense attorney when facing a charge to better understand what potential defenses may be available and what the consequences may arise as a result of pleading guilty to a crime.

Sources:

WFMY News, “Wayne Holyfield No Show In Court; 90 Traffic Cases ‘Dismissed’,” April 30 2012

WFMY News, “Candor Commissioner Wayne Holyfield Refuses To Resign Despite Community Demands,” April 10, 2012

Greenville DUI Attorney Blog | North Carolina Underage Drinking Lawyer | Pitt County First DUI Law Firm

New proposed legislation has been introduced in Congress aimed at increasing the use of ignition interlock devices in drunk driving cases nationwide. North Carolina law added the use of ignition interlocks last year in DWI cases involving alcohol readings of 0.15 percent or greater and for people convicted of DWI within seven years of a previous conviction. States generally define their own DWI laws under the separation of powers doctrine.

Congress is now considering using its purse strings to dictate to the states when to require ignition interlocks in DWI cases. Roughly 15 states already require interlocks in all cases, including first time DWI cases. However, the congressional proposal is not characterizing the measure so much as one to promote safety, but as a federal jobs measure.

The proposal in Washington is part of a transportation bill that would offer states more federal money for increasing the use of ignition interlocks. Currently in North Carolina, the devices are programmed to prevent vehicles from starting if the driver blows a 0.02 percent or more blood alcohol level before trying to start the car. North Carolina lawmakers have defined certain cases that lawmakers here believe justify the use of the portable breath test machines.

The American Beverage Institute says mandating use of the interlocks would take discretion away from judges in sentencing a defendant. The portable Breathalyzer-type machines also may not be as sophisticated as the magic boxes that the state relies upon to determine guilt or innocence in DUI cases, machines that have raised questions concerning reliability across the country.

The current proposal in the U.S. House is part of a massive transportation bill. The federal legislation apparently does not take into account a state’s individual decisions on when to use the devices. The Senate is expected to consider a measure similar to the House bill in the near future.

Source: Los Angeles Times, “Drunk drivers: Congress gets behind breath-test ignition devices,” Richard Simon, Jan. 31, 2012

Greenville DUI Attorney Blog | North Carolina Underage Drinking Lawyer | Pitt County First DUI Law Firm

North Carolina’s underage drinking laws can be broad and apply to people who are not at the scene of an underage drinking incident. Earlier this month, this blog reported that a Raleigh teen is facing a slew of charges in relation to an alleged drunk driving crash that followed a high school party that allegedly including underage drinking.

North Carolina authorities now report that additional charges have been filed in relation to the alleged events that happened on January 7. Special agents with North Carolina Alcohol Law Enforcement say that they arrested a 21-year-old Raleigh man in connection with the case. The man has been charged with four counts of aiding and abetting underage possession of alcohol.

Two of the counts relate to the two teens who were involved in the January 7 accident. Agents believe the Raleigh adult may have provided alcohol to the driver accused of DWI in the fatal car accident and also to the young woman who died in the crash. The driver is facing charges ranging from felony death by motor vehicle to provisional DWI and a variety of other charges.

Two other aiding and abetting counts against the 21-yuear-old Raleigh man apparently relate to two other females who were not involved in the accident.

ALE officials claim the Raleigh adult purchased two 1.75-liter containers of flavored rum at the Wake County ABC store on January 6.

The high school party and the car accident that reportedly followed the party remain under investigation. ALE agents say that additional charges are likely in relation to the investigation.

Source: Raleigh Telegram, “Police Charge Man With Giving Alcohol To Raleigh Students In Deadly Crash,” Jan. 23, 2012

Greenville DUI Attorney Blog | North Carolina Underage Drinking Lawyer | Pitt County First DUI Law Firm