The Supreme Court of the Commonwealth of the Northern Mariana Islands (CNMI) upheld the conviction of Anthony S. Peters for driving under the influence (DUI) of alcohol. The court ruled that Peters did not have a constitutional right to a jury trial in this case and that the breathalyzer test results were admissible. This decision is significant for individuals facing similar DUI charges in the CNMI.
The case, Commonwealth v. Peters, was filed under docket number 90-026 on January 8, 1991. The court, led by Justice Borja and including Chief Justice Dela Cruz and Special Judge Atalig, heard arguments on November 6, 1990. The ruling affects how DUI cases are prosecuted in the CNMI, particularly regarding the rights of defendants and the admissibility of evidence.
Peters was arrested on January 16, 1988, after a police officer observed him driving a silver sedan at a high speed. The officer noted that Peters appeared intoxicated, with a flushed face, bloodshot eyes, and slurred speech. Peters failed two field sobriety tests and later registered a blood alcohol concentration (BAC) of .181 on a breathalyzer test. He was charged with DUI under 19 CMC § 7105(a), which prohibits driving with a BAC of 0.10 or more.
Initially, Peters requested a jury trial, but the trial court denied this motion. Instead, a bench trial took place on December 7, 1988, where Peters was convicted. At trial, the prosecution did not provide evidence that the breathalyzer was properly calibrated before the test was administered. Peters did not present any evidence in his defense.
The key issues in this case revolved around Peters' right to a jury trial and the admissibility of the breathalyzer test results. Peters argued that the right to a jury trial is a fundamental constitutional right that should apply in the CNMI, especially since the CNMI has joined the American political family. He cited a previous case, CNMI v. Atalig, to support his claim that the reasoning in that case should be reevaluated.
The court ruled that Peters' arguments lacked merit, stating, "We agree with the government that the constitutionality of covenant section 501 has been addressed and authoritatively resolved in the Atalig case." The court found no reason to question the Atalig case and concluded that Peters did not have a constitutional right to a jury trial in this instance.
Regarding the breathalyzer test results, the court addressed whether Peters could claim error due to the lack of objection to the evidence's admission. The court noted that under 9 CMC § 7107, the results of breathalyzer tests are admissible in court. The court stated, "A reasonable interpretation of this statute is that the result of such test is admissible." Since Peters did not object to the admission of the test results, the court held that he could not claim error.
The ruling has implications for future DUI cases in the CNMI. It clarifies that defendants in DUI cases may not have an automatic right to a jury trial and that breathalyzer test results can be admitted as evidence even without prior objection. This decision may influence how defendants approach their legal strategies in similar cases.
Looking ahead, Peters' conviction may be subject to appeal, but details were not available in the court filing regarding any pending appeals or related cases. The court's decision sets a precedent for how DUI cases are handled in the CNMI, particularly concerning defendants' rights and the use of breathalyzer evidence.