Motor Vehicle Administration v. Krafft

These two cases concerned administrative hearings in cases where an individual suspected to have been driving (or attempting to drive) while impaired refuses to take a breath test for blood alcohol concentration. In each case, an administrative law judge (ALJ) overturned the suspension on the ground that it was not established by a preponderance of the evidence that the individual had actually been driving (or attempting to drive) at the time the individual was detained by a law enforcement officer. The Supreme Court vacated the judgment in one case and reversed the judgment in the other case, holding (1) in a test refusal case, there is no requirement that the Motor Vehicle Administration prove that the individual was actually driving (or attempting to drive) while under the influence of alcohol; rather, the relevant question is whether the officer had reasonable grounds to believe that the individual was driving (or attempting to drive) while under the influence of alcohol; (2) in one case, the ALJ found that the officer had reasonable grounds, and thus the suspension should have been upheld; and (3) in the other case, the ALJ’s finding on the issue of reasonable grounds was ambiguous, and the case is remanded for clarification. View "Motor Vehicle Administration v. Krafft" on Justia Law