Question juridique clé
Whether the administrative authority was bound by the facts found in the summary criminal decision or could determine independently that the driver had fallen asleep.
Solution extraite
The administrative court could depart from the criminal summary decision because the driver had not been informed that an administrative withdrawal would be based on drowsiness, and later testimony provided new elements.
Motifs extraits
A criminal judgment normally binds the licensing authority, but exceptions apply where new facts emerge or where the criminal decision did not address the relevant issue. Here the summary decision contained no findings on sleep, the driver had no reason to contest it further, and his later explanations before the administrative court justified an independent assessment.