Understanding Commonwealth v. Brian Sanchez: DUI Conviction and Constitutional Challenges

Commonwealth v. Sanchez, 2024 Pa. Super. 245 (Pa. Super. Ct. 2024)

Understanding Commonwealth v. Brian Sanchez: DUI Conviction and Constitutional Challenges

The Pennsylvania Superior Court recently issued a decision in Commonwealth v. Brian Sanchez, 1680 MDA 2023, affirming the conviction of Brian Sanchez for Driving Under the Influence (DUI) of a controlled substance. The case raised significant legal questions, including the constitutionality of Pennsylvania’s DUI statute regarding marijuana and the legality of the traffic stop that led to Sanchez’s arrest. This article provides an in-depth analysis of the facts, legal arguments, and the court’s reasoning.

Case Background

On May 6, 2022, at approximately 1:25 a.m., Pennsylvania State Trooper Jeffrey Allen initiated a traffic stop in Oxford Township, Adams County, PA. The stop was based on a loud and modified exhaust system, which Trooper Allen believed violated the Pennsylvania Vehicle Code.

Upon approaching the vehicle, Trooper Allen observed the following:

• The driver, Brian Sanchez, had bloodshot and glassy eyes.

• There was a slight odor of marijuana emanating from the vehicle.

• Sanchez admitted to having smoked marijuana earlier that evening and possessed a THC dab pen.

• Sanchez failed multiple field sobriety tests, including the Horizontal Gaze Nystagmus (HGN), Walk and Turn, and One-Leg Stand tests.

Following the investigation, Sanchez was arrested and charged with DUI under 75 Pa.C.S.A. § 3802(d)(1)(i) and (iii) for operating a vehicle with a controlled substance in his system.

Legal Challenges and Arguments

Sanchez filed an omnibus pretrial suppression motion, arguing:

1. The Traffic Stop Was Unlawful

   • Sanchez argued that a loud exhaust does not provide reasonable suspicion for a stop.

   • The court rejected this, holding that officers can stop a vehicle based on an observed traffic violation.

2. Lack of Reasonable Suspicion for a DUI Investigation

   • Sanchez contended that Trooper Allen had no reason to believe he was under the influence.

   • The court found that the odor of marijuana, bloodshot eyes, and admission of recent marijuana use provided reasonable suspicion to continue investigating for DUI.

3. DUI Statute is Unconstitutional

   • Sanchez challenged Pennsylvania’s DUI law, specifically 75 Pa.C.S.A. § 3802(d)(1)(i) and (iii), on equal protection and due process grounds.

   • Equal Protection Argument: Sanchez argued the law discriminates against medical marijuana users by criminalizing any detectable level of THC, unlike other prescription medications.

   • Due Process Argument: He contended the law is arbitrary and punishes individuals who are not impaired but merely have residual THC in their system.

   • Court’s Ruling:

     • The court ruled that Sanchez lacked standing to challenge the law’s impact on medical marijuana users since he did not possess a medical marijuana card at the time of his arrest.

     • Even if he had standing, the court found the DUI statute constitutional, citing Commonwealth v. Smith, 320 A.3d 674 (Pa.Super. 2024), which upheld the law’s validity.

Court’s Decision

On November 13, 2023, Sanchez was sentenced to:

• 6 months’ probation

• 10 days of house arrest

• Fines and court costs

Sanchez appealed, arguing that the trial court erred in denying his suppression motion and upholding the constitutionality of the DUI statute. However, the Pennsylvania Superior Court affirmed his conviction, holding:

1. The traffic stop was lawful based on a legitimate Vehicle Code violation.

2. Reasonable suspicion existed for a DUI investigation due to physical signs of impairment, odor of marijuana, and the defendant’s own statements.

3. The DUI statute is constitutional, and Sanchez lacked standing to challenge it.

Key Takeaways from Commonwealth v. Brian Sanchez

1. Pennsylvania’s DUI Laws for Marijuana Remain Strict

• Under 75 Pa.C.S.A. § 3802(d)(1), any detectable level of THC in a driver’s blood can lead to a DUI conviction, even if the driver is not impaired at the time.

• This contrasts with alcohol-related DUIs, where impairment must be demonstrated above a certain threshold (0.08 BAC).

2. Law Enforcement Can Investigate DUI Based on Minimal Indicators

• The odor of marijuana and physical signs of impairment are sufficient to justify a DUI investigation.

• Admission of marijuana use, even hours before driving, can be used against a driver.

3. The DUI Law’s Constitutionality Has Been Upheld

• Courts have repeatedly ruled that the law does not unfairly target medical marijuana users.

• Equal protection and due process arguments have failed in Pennsylvania appellate courts.

The Commonwealth v. Brian Sanchez case reinforces the broad authority of law enforcement to conduct DUI investigations based on suspected marijuana use. It also underscores the strict application of Pennsylvania’s DUI laws for cannabis users, even in the wake of the state’s Medical Marijuana Act. Until legislative reforms address the zero-tolerance policy for THC, individuals using cannabis—medically or recreationally—must be aware of the legal risks of driving in Pennsylvania.

Need Legal Representation for a DUI Charge?

At The Town Law LLC, our experienced criminal defense attorneys in Philadelphia are dedicated to protecting your rights in DUI and drug-related cases. Whether you’re facing charges for marijuana DUI, prescription medication impairment, or alcohol-related offenses, our team provides aggressive defense strategies to help you achieve the best possible outcome.

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