Supreme Court of Connecticut

State v. King

February 28, 2023346 Conn. 238

Summary

The court held that an out-of-state DUI statute has essential elements substantially the same as Connecticut's DUI statute when the basic and necessary components of the offenses, including actus reus, mens rea, and causation, are the same to a considerable degree. Applying that standard, it concluded that Florida's actual-physical-control element substantially matched Connecticut's operating element because both require conduct placing an intoxicated person in a position to make the vehicle operative, rather than merely sitting or sleeping in the vehicle. The court therefore upheld the defendant's sentence enhancement as a third-time offender.

Holding

  • Meaning of essential elements and substantially the same under the DUI sentence-enhancement statute. The essential elements of an out-of-state offense are substantially the same as those of Connecticut's DUI offense when the offenses' basic and necessary parts, including actus reus, mens rea, and causation, are the same to a considerable degree. Courts must compare the statutory elements and their legal definitions, not the facts underlying the particular out-of-state conviction.
  • Whether Florida's actual-physical-control element is substantially the same as Connecticut's operating element. Florida's actual-physical-control element is substantially the same as Connecticut's operating element for purposes of the Connecticut sentence-enhancement statute.

Docket SC20588

Cited authorities

  • N.Y. Law § 90
  • Fla. Stat. Ann. § 316.193
  • Fla. Stat. Ann. § 316.193
  • Fla. Stat. Ann. § 316.193
  • Fla. Stat. Ann. § 316.193
  • Fla. Stat. Ann. § 316.193
  • Fla. Stat. Ann. § 316.193
  • Fla. Stat. Ann. § 316.193

Cited by