State v. Fitzgerald, 63 So. 3d 75 (Fla. Dist. Ct. App. 2d Dist. 2011)"In felony driving under the influence (DUI) case, State satisfied its burden to prima facie demonstrate that defendant was in actual physical control of a motor vehicle while under the influence of alcohol so as to survive motion to dismiss; defendant was sitting in the driver's seat and she readily produced the car keys, there was no evidence that she needed to search for the keys or that she retrieved them from the passenger, car was stopped in an intersection with its lights on, legitimate inference to be drawn was that defendant placed herself behind the wheel and at any time could have started the car and driven away, and keys were close enough for defendant to use them to start the car and drive away."