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Case Brief - CJUS Writing
Criminal Justice Research and Writing (Liberty
University)
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Caption
Lambert v. Commonwealth, 70 Va. App. 54 (2020)
Facts
On March 1, 2015, Donna Turner was driving eastbound in Russell county crossing “Big A”
mountain. Passenger, Forrest Ramsey, was in the front seat. At the same time, Clinard Gary
Lambert was driving westbound approaching her on the same road. The defendant crossed the
centerline, entering the eastbound lane and continued gliding until he hit the guardrail. He
scraped along the guardrail for about forty feet before stopping. Donna Turner saw the
defendant’s vehicle and tried to swerve to avoid collision but was unsuccessful. Donna suffered
major injuries, but her passenger, Forrest Ramsey, got the brunt of the impact and later died as a
result of the intense force of impact. There were several witnesses that appeared on the scene.
Two witnesses mentioned Lambert having “slurred speech” and was “wobbling” when walking
out of the vehicle. When cops arrived at the scene, they asked Lambert if he had been consuming
either alcohol or drugs, Lambert denied both. After being asked a second time, the defendant
admitted to just having a “treatment of methadone.” Lambert was transferred to Holston Valley
Hospital in Kingsport, Tennessee where his blood was taken and tested. The results showed the
defendant having methadone, Valium and Xanax in his system. Lambert was charged with
involuntary manslaughter and driving while intoxicated.
Procedural History
The case was presented to a Grand Jury in the Circuit Court in Russell County. The defendant
was indicted for involuntary manslaughter and also for driving while intoxicated. The case was
then presented to a jury trial and Lambert was found guilty on both charges. Lambert then
appealed the case to the Court of Appeals and an appeal was granted.
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Issue
Whether or not Lambert took the drugs himself that were found in his system.
Rule of Law
It shall be unlawful for any person to drive or operate any motor vehicle while such person is
under the influence of any type of self-administered drug or drug combination. Any person that
causes the death of another person while under the influence will be charged with involuntary
manslaughter.
Holding
After first denying having taken any drugs, Lambert admitted to having a “treatment of
methadone” at a clinic. Methadone clinics are voluntary, so Lambert’s use was completely
voluntary.
Rationale
Per Va. Code § 18.2-266, Lambert’s rationale to appeal his conviction would have had to self-
administer the drugs in order to have been found guilty. Without proof that the drugs were self-
administered, there’s no way for Lambert to be found guilty of driving while intoxicated, and so
cannot be charged with involuntary manslaughter. However, the court found that the term “self-
administered” was not needed to convict Lambert of the charges against him. Lambert not only
had drugs in his system while driving, but he also tried to conceal that fact when initially asked
at the scene. Telling the truth the second time he was asked did not help his case, as he already
tried lying. The fact that methadone treatments are completely voluntary, the issue of whether
or not the drugs were self-administered is not relevant anymore in Lambert’s case and he will
be found guilty on both charges.
