CJUS230 Case Brief
Caption
Clinard Gary Lambert v. Commonwealth of Virginia, v Record No. 190439 (2020)
Facts
Clinard Gary Lambert was in his pickup truck driving westbound on March 1, 2025. During his
drive, he crossed over the center line of the road, continued to crash into a guardrail, then
finally came to a stop in the wrong lane. There was an individual who was driving eastbound
named Donna Turner. When the accident occurred, she attempted to swerve out of the way but
collided with the Lamber’s truck. Turner sustained some injuries from the accident but her
passenger, Forrest Ramey died in the crash from blunt force trauma injuries. Lambert was
described by some witnesses on the scene by being wobbly, dazed, and having slurred speech.
Emergency responders on the scene noted the impaired state that Lambert was in and the
presence of Xanax, Valium, and methadone in his system was later detected by a forensic
toxicology report. At first, Lambert denied taking drugs but then later confirmed that he had
received methadone at a treatment clinic.
Procedural History
In the Circuit Court of Russell County, Lambert was both charged and convicted for driving while
intoxicated and aggravated involutory manslaughter. He appealed this ruling with the Court of
Appeals of Virginia. This court affirmed the original court’s ruling. However, the Supreme Court
of Virginia granted an appeal that was limited to the issue of if there was sufficient evidence to
be able to prove the Lambert had administered the intoxicants to himself that had impaired his
ability to safely drive.
Issue
Was there enough sufficient evidence to be able to prove, beyond a reasonable doubt, that
Lambert had administered the drugs to himself that had negatively affected his ability to safely
drive?
Rule of Law
The § 18.2-266 code of Virginia states that it is against the law for someone to drive a vehicle
while under the influence of a self-administered intoxicant or drug that impairs their ability to
safely drive. It provided under code § 18.2-36.1(A) that a person who causes the unintentional
death of another individual as the direct result of driving while intoxicated is to be found guilty
of involuntary manslaughter.
Holding
Yes, the Supreme Court of Virginia held that there was sufficient evidence to support the
conclusion that Lambert had administered intoxicants to himself that had impaired his ability to
drive. This also affirms the judgement placed by the Virginia Court of Appeals.
Rationale
The Virginia Court found that Lambert had voluntarily in a treatment program for methadone
then later admitted to having received the drug. The presence of multiple substances was
detected in a toxicology report. These substances are known to impair motor ability and were
confirmed, through the testimony of experts, that their combined effects are dangerous.
Lambert’s impairment on the scene was observed through his lack of balance and slurred
speech. His impairment supported the speculation that Lambert was under the influence. The
jury could also rationally interpret the evidence of conscious guilt through Lambert’s initial false
statements.
Conclusion
The Virginia Supreme Court affirmed the convictions placed on Lambert which ruled that there
was sufficient evidence for a rational jury to deduce that he had administered the drugs that
were found in his system to himself. Furthermore, that this action led to the impairment that
caused the fatal incident.
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