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.