Commonwealth v. Shaffer
40 A.3d 1250
| Pa. Super. Ct. | 2012Background
- Shaffer was stopped for erratic driving by Trooper David; blood alcohol content later measured at 0.15%.
- Shaffer was arrested after failing field sobriety tests and transported to Gettysburg Hospital for blood testing.
- At trial, the Commonwealth presented Trooper David and lab analyst Christina Zurad; blood drawn by phlebotomist Rachel McGlaughin and sealed for transport.
- Zurad testified to the lab process and that Shaffer's blood sample was analyzed, with a report stating BAC 0.150% within two hours of driving.
- Shaffer was convicted of DUI–High Rate of Alcohol and sentenced to six months in IPP; he appealed asserting confrontation and weight-of-evidence issues.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Confrontation rights and lab testing testimony | Shaffer contends Melendez-Diaz requires confronting the phlebotomist. | Shaffer argues the phlebotomist should have testified or his absence violated confrontation. | Confrontation not violated; lab analyst testimony sufficed and no report from phlebotomist existed. |
| Weight of the evidence | Weight claim rests on absence of phlebotomist as witness. | Shaffer contends verdict against weight of evidence due to lack of phlebotomist testimony. | No weight-of-the-evidence error; properly admitted lab report and credibility support the conviction. |
Key Cases Cited
- Melendez-Diaz v. Massachusetts, 557 U.S. 305 (2009) (confrontation required for testimonial lab reports; chain-of-custody context discussed)
- Commonwealth v. Champney, 574 Pa. 435 (2003) (weight-of-the-evidence standard; appellate review limited to abuse of discretion)
- Department of Transportation v. O'Connell, 521 Pa. 242 (1989) (concerning conformance of chain-of-custody and related procedures)