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

• In the early morning of October 5, 2013, an officer responded to a single-vehicle accident involving the Defendant, who was found in the driver's seat with signs of alcohol consumption. After failing a horizontal gaze nystagmus test and complaining of pain, the Defendant was taken to a hospital where she consented to a blood draw. The blood test indicated her blood alcohol content was over the legal limit, leading to charges of driving under the influence (paras 2-3).

Procedural History

• Metropolitan Court: The trial court suppressed the blood test evidence, ruling in favor of the Defendant based on the confrontation clause, as the phlebotomist who drew the blood did not testify (para 4).
• District Court of Bernalillo County: Reversed the metropolitan court's suppression ruling, allowing the blood test results without the phlebotomist's testimony (para 1).

Parties' Submissions

• Defendant-Appellant: Argued that the phlebotomist's testimony was necessary to establish qualifications and compliance with blood-draw procedures, invoking the right to confrontation under the Sixth Amendment (para 6).
• Plaintiff-Appellee (State): Contended that the officer's testimony could provide the necessary foundation for the blood draw, and compliance with Section 66-8-103 is foundational, thus not subject to confrontation clause guarantees (paras 4-5).

Legal Issues

• Whether the district court erred in allowing the introduction of blood test results without the testimony of the phlebotomist, in light of the Defendant's right to confrontation (para 6).

Disposition

• The Court of Appeals affirmed the district court's decision, allowing the blood test results without the phlebotomist's testimony (para 17).

Reasons

• Per LINDA M. VANZI, Chief Judge (HENRY M. BOHNHOFF, Judge, EMIL J. KIEHNE, Judge concurring): The court held that compliance with Section 66-8-103 and the qualifications of the phlebotomist are foundational and non-testimonial facts that do not implicate the Confrontation Clause. The court distinguished this case from others by emphasizing that foundational issues related to the accuracy of the blood draw do not require the same level of scrutiny under the Confrontation Clause as testimonial statements. The court also noted that the Defendant had the opportunity to challenge the phlebotomist’s qualifications or the procedure used to draw blood by taking steps to introduce relevant evidence at trial (paras 6-16).