State v. Peyton Closing Argument

Felony hit and run argument 1

1. Jordan Peyton was driving her car when she knew she struck Taylor Addison's car Knew that she hit the car but is blaming iit on the potholes on the road - Circumstantial evidence -- Riley's tweet "Made it home-barely" --Riley testified that Peyton is known to be a fast driver around the office --- Bumpy ride Few potholes on the road would not cause someone to consider in such a short time that the entire ride had been bumpy enough to devote an entire tweet to it Peyton was impaired from the alcohol and her ability to drive became erratic and unsafe Lost control of the vehicle due to her impairment and that's when her car hit Addison's parked car. ---- Trying to get as far away from the accident as possible Failed to stop and denies hearing Addison honking her horn but she was within hearing distance and they were not listening to the radio in the car Stopped and talked to Riley after she dropped him off Must have talked to Riley for 15-20 minutes because Officer Baldwin did not find her at her house for at least 30 minutes after the accident and she was just arriving home when he was arriving. During this time did they discuss their plan? Had ample time before Riley gave his statement to police a week later Riley and Peyton had a friendly relationship: buying him beers at events, worked on projects together, he seemed enthralled by her during his statement calling her a generous person Removed the logo from her car immediately after the accident Did not want to be recognized during evidence collection Car was not where it was parked the night after the accident Officer Baldwin did not locate it till days later in her work parking garage so that he could collect paint samples ----- Going slow through the following intersection Trying to slow down to see who she hit Not on brand for her to be driving slow and careful Charged with reckless driving and plead guilty in the past Riley testified that she is known to be a fast driver Riley's tweet

DUI argument 1

1. Jordan Peyton was the driver of her silver Mercedes that night Mercedes Addison saw the Mercedes driving away from the accident Addison saw the color to be either silver or white with the Peyton & Dalton logo on the side of the car Officer Baldwin searched employees at the firm and Peyton came up registered to a silver mercedes and lived close to the accident Officer Baldwin visited her apartment and saw Peyton parking her Mercedes Peyton admitted to offering to give Riley a ride home while at the bar

felony hit and run argument 2

2. As a result of the impact, Taylor Addison spilled her hot coffee all over her right hand and suffered debilitating second degree burns Addison dropped the coffee and threw it out her window

DUI argument 2

2. She was driving down 2nd Avenue on her way to drop Riley off Admitted Officer Baldwin that she had driven down that street on her way to take Riley home "Came up First or Second avenue to North Market"

felony hit and run argument 3

3. Peyton did not stop the car and continued driving, she failed to report her name, address, driver's license number, vehicle registration to a local law enforcement agency and to Taylor Addison, the person struck who was injured but capable of understanding and retaining information Continued to drive even after hitting the car

DUI argument 3

3. She was under the influence of alcohol to a degree that impaired her ability to drive or operate her motor vehicle safety because she had drunk a minimum of 3 beers within her two hours at the bar all on an empty stomach. -- Bloodshot and glassy eyes -- Smelt of alcohol -- Failed 3 different sobriety tests Tried to distract the officer and end the test when her cell phone rang by asking him if she could answer it Used excuse that her legs were hurting Asked to do the final test again once she realized she did bad Combative and argumentative with the officer Yelling at him after arrest Belittling him -- 3 beers while at the bar Peyton had a receipt with 7 beers on it Admitted to drinking 2 beers Riley had 5 beers total but paid for 1 himself 3 of the beers were drunk by Peyton -- Empty stomach Had not eaten since lunch, a minimum of 5 hours before she had her first drink -- Drank within 2 hours or less Arrived at the bar around 5:15/5:20 Left the bar at 7:15 pm -- Circumstantial evidence --- Celebrating a big deal that the company sealed Why she offered to buy Riley beers End of a long day Testified herself within her statement after arrest Back to back meetings --- Event was a happy hour Riley testified in his statement to Officer Baldwin that he often saw Ms. Peyton drink at work happy hours --- Riley's tweet "Made it home-barely" --- Riley testified that Peyton is known to be a fast driver around the office --- Bumpy ride Few potholes on the road would not cause someone to consider in such a short time that the entire ride had been bumpy enough to devote an entire tweet to it ---- Peyton was impaired from the alcohol and her ability to drive became erratic and unsafe ---- Lost control of the vehicle due to her impairment and that's when her car hit Addison's parked car. ---- Doesn't remember which route she took home ---- Familiar with the streets and had driven the road numerous times ---- Car ride only lasted 5-10 minutes Remembered the conversation she had with Riley but failed to remember where she was driving? ---- Doesn't remember hearing any horn Would have been within a close distance and would have heard the horn if she was paying attention to the road

opening

Beware of the wolf in the sheep's clothing. The wolf is someone who will lie in order to get their way and to ensure they end up on top. A wolf has no place in this courtroom. Jordan Peyton is the wolf; she has continuously lied and muddled her story of what occurred the night of the accident to make sure she ends up on top. On May 15, Jordan Peyton went to a work happy hour. She drank to the point where she was impaired and could not safely drive, she got into her car, a silver Mercedes, with her co-worker Riley Cameron, and hit Taylor Addison's car. She hit the car so hard that Taylor Addison spilt burning hot coffee all over her right hand and suffered second degree burns. Jordan Peyton immediately fled the scene. She didn't stop to see if Ms. Addison was okay, she didn't stop to give her statement to law enforcement, and she didn't take any responsibility for the injury she caused. She lied about how many drinks she had that night, pretended that she hit a few potholes, and tried to escape without facing the consequences of her careless actions. Jordan Peyton drove her car while under the influence of alcohol to a degree that impaired her ability to drive safely and knowingly hit Ms. Addison's car on her way home. Jordan Peyton is the reason that Ms. Addison can no longer work and has to live with second-degree burns the rest of her life.

burden of proof

Beyond a reasonable doubt Must prove all of the legal elements given within the jury instructions

jury instruction for DUI

For driving under the influence, the State must prove all the following : 1. While operating a motor vehicle 2. On a public roadway 3. The defendant was under the influence of alcohol, or other self-administered intoxicant or drug of any nature, or any combination of such drugs, to a degree as to impair his/her ability to drive or operate a motor vehicle safely

background

Over the course of the trial, you have gotten to know who Jordan Peyton is. Jordan Peyton as a successful owner of her own company is used to getting things she wants. She is used to doing whatever it takes to come out on top so that she can continue to live the lavish life that she has created for herself. This is not the first time she has broken the law and lied about it- charged and found guilty of larceny and instead of owning up to her theft she lied and blamed it on another person she was with. She has a reputation in her firm for driving fast and recklessly. Jordan Peyton is not afraid to break the rules and believes she should suffer no repercussions from breaking them and we saw her true colors come out when she was arrested. She carried this attitude with her while she was interacting with Officer Baldwin; she was rude to him, belittling, and combative. When it comes to the law, she has a problem owning up to her own actions and admitting when she is wrong.

jury instructions for felony hit and run

To prove felonious hit and run the State must prove all the following: 1. While operating a motor vehicle, the defendant knew that he or she was involved in an accident Knew or should have known 2. As a result of the accident, a person was injured or an occupied vehicle was damaged; and 3. The defendant failed to stop as close to the scene of the accident as possible without obstructing traffic and report his or her 1. Name, 2. Address, 3. Driver's license number, 4. Vehicle registration to local law enforcement agency, and 1) to the person struck of injured if that person seems capable of understanding and retaining the information Accident defined as any unintentional or international contact between a motor vehicle and another motor vehicle that results in damage, no matter how slight