AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

• The Defendant, Alvin P. King, was convicted of per se DWI for driving with an alcohol concentration of .08 or higher. During the trial, the State's only witness, Officer Devin Largo, testified about stopping the Defendant for a possible seat belt violation, observing signs of intoxication, and performing a breath alcohol test using an Intoxilyzer 8000 machine. The Defendant sought to challenge the reliability of the Intoxilyzer 8000 machine's results by proposing expert testimony from Dr. Edward Reyes, a pharmacology and toxicology expert with an analytical chemistry background and training in the use of the Intoxilyzer 8000 (paras 2-3).

Procedural History

• [Not applicable or not found]

Parties' Submissions

• Plaintiff-Appellee (State): Argued that the district court correctly refused to allow the Defendant to present expert testimony challenging the reliability of the Intoxilyzer 8000 machine because the expert had not examined the specific machine used and such testimony would not be relevant given state law authorizing the use of an intoxilyzer machine (paras 4, 10, 14).
• Defendant-Appellant: Contended that the district court erred by not allowing Dr. Reyes to testify about the reliability and accuracy of the Intoxilyzer 8000, arguing that his testimony would be based on the common structure, mechanisms, and workings of all Intoxilyzer 8000 machines, which would be relevant to challenging the reliability of the machine used in his case (paras 3, 12).

Legal Issues

• Whether the district court erred by refusing to allow the Defendant to present expert scientific testimony on the reliability and accuracy of the intoxilyzer machine used to determine his breath alcohol content.
• Whether the district court violated the Defendant's confrontation rights by allowing the admission of his breath test result without live testimony from the key operator or an expert from the Scientific Laboratory Division (SLD).

Disposition

• The Court of Appeals reversed the Defendant's conviction and remanded for a new trial, holding that the Defendant was entitled to present expert testimony challenging the reliability of the Intoxilyzer 8000. The Court did not reach the Defendant's confrontation issue (para 23).

Reasons

• The Court of Appeals, with Judge James J. Wechsler authoring the opinion, held that the district court abused its discretion by refusing to admit Dr. Reyes' expert testimony. The Court reasoned that Dr. Reyes' testimony would assist the trier of fact in understanding the evidence or determining a fact in issue, specifically the reliability of the Intoxilyzer 8000 machine's results. The Court found that the district court's reasons for excluding the testimony—namely, that Dr. Reyes had not examined the specific machine used, that his testimony would not be relevant due to state law authorizing the use of intoxilyzer machines, and that the testimony would either not be probative or its prejudicial effect would outweigh its probative value—were not supported by the rules of evidence. The Court concluded that the expert's failure to examine the machine in question did not preclude his testimony and that challenges to the reliability of intoxilyzer results are permissible even when the machine has been approved and operated in accordance with SLD regulations (paras 5-22).