Supreme Court of Delaware

Steele v. State

April 19, 2024

Summary

The Court affirmed Steele’s conviction for driving under the influence. Because Steele did not move for judgment of acquittal, the Court reviewed his sufficiency claim for plain error and found none. The Court held that the officer’s observations and testimony, including evidence of alcohol odor, drug-related indicators, confusion, belligerence, and Steele’s admission that he had consumed vodka, were sufficient for a rational jury to find guilt beyond a reasonable doubt, even without a blood draw or corroborating physical evidence.