Absolutely. When my son was stationed in Kansas years ago I was talking to a young guy there.
He had multiple Dui against him. Told me he was drinking came out got in his car no keys to get something from the car
It was on the property not running no keys . They hit him with another Dui and it stuck.
In Kansas, at least when I was working, keys had to be in the ignition (vehicle engine on or off) and suspect in the drivers seat for a DUI charge. Of course we could exercise discretion and I often did generally based on their attitude.