State of Arkansas v. Michael Aud

Summary

The Supreme Court of Arkansas dismissed the State's appeal from Michael Aud's acquittal on a driving-while-intoxicated charge. The court held that the appeal concerned the trial court's fact-specific assessment of breathalyzer evidence and witness credibility, rather than an issue involving the correct and uniform administration of criminal law under Rule 3. Two justices dissented, concluding that the case presented a significant statutory-interpretation issue concerning the effect of a 0.10% breathalyzer reading.

Holdings

1. The State's appeal was not properly reviewable because it involved only the trial court's fact-specific consideration of the evidence rather than an issue of legal interpretation with widespread ramifications affecting the correct and uniform administration of criminal law.

Questions Presented

1. Whether the State's appeal from Aud's acquittal presented an issue involving interpretation of criminal law or criminal rules with widespread ramifications and therefore qualified for review under Rule 3(c).
2. Whether the trial court's acquittal rested on a broad legal determination that breathalyzer results are unreliable or instead on its fact-specific evaluation of the evidence and witness credibility.

Disposition

dismissed