Wiyott v. State
In Wiyott v. State, 284 Ark. 399, 683 S.W.2d 220 (1985), appellant was found behind the steering wheel of a vehicle, with the key in the ignition; he attempted to start the vehicle when he awoke; and there was no evidence anyone else had control over the vehicle.
The court noted: "The evidence would support the finding that appellant was exercising direct influence over his vehicle and had the authority to manage it. At any moment he could have awakened and started his vehicle." Id. at 402.