AI Generated Opinion Summaries

Decision Information

Decision Content

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 was charged with driving while intoxicated. During the investigation, an officer administered a portable breath test (PBT) to the Defendant. The Defendant later contended that the officer's lapel video recording, which was supposed to capture the entire interaction, was incomplete as it did not include the administration of the PBT. The Defendant argued that the missing video footage could have potentially contained exculpatory evidence.

Procedural History

  • [Not applicable or not found]

Parties' Submissions

  • Defendant-Appellant: Argued that the metro court erred in denying his motion to suppress officer testimony due to an alleged deficiency with the officer’s lapel video recording, claiming the incomplete video did not capture the officer administering a PBT, which could have been exculpatory (paras 2-3).
  • Plaintiff-Appellee: The specific arguments of the Plaintiff-Appellee are not detailed in the provided text, but it can be inferred that the Plaintiff-Appellee opposed the Defendant-Appellant's motion and supported the decisions of the metro and district courts.

Legal Issues

  • Whether the metro court erred in denying the Defendant's motion to suppress officer testimony based on the alleged deficiency with the officer’s lapel video recording.

Disposition

  • The Court of Appeals affirmed the district court’s on-record review and affirmance of the metro court’s judgment and sentence entered following the Defendant's conditional plea of guilty to driving while intoxicated (para 1).

Reasons

  • Per M. Monica Zamora, with Michael D. Bustamante and Roderick T. Kennedy concurring, the Court found that the Defendant did not meet the burden of demonstrating that the metro court erred in denying his motion to suppress. The Court agreed with the district court's analysis, applying the two-part test from State v. Ware to determine the materiality of the missing video footage and the appropriateness of the officer's conduct. The Court also agreed with the district court that the standard of review for the denial of a motion to sanction by dismissal or suppression of evidence is abuse of discretion, rejecting the Defendant's argument for a de novo review based on an inapposite citation to State v. Sewell. The Court concluded that the Defendant's arguments did not demonstrate any error in fact or law in the metro court's decision or in the district court's affirmance of that decision (paras 2-5).
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