Kyle L. Doolin v. State of Indiana, 2012 Ind. App. LEXIS 333

Deputy Petree stopped a car for a lane-change signal issue; Doolin was a front-seat passenger and admitted ownership of marijuana during jail questioning.
A velvet bag with two baggies of plant material (suspected marijuana) was found in the glove box; the material was not tested before trial.
Deputy Petree conducted an in-court field test; a second test indicated THC presence.
Doolin was convicted of possession of marijuana; other counts were acquitted; sentence was 365 days with probation.
Doolin objected to the field test’s admission, arguing lack of reliability foundation under Rule 702.
The court held the field test’s admission was error but harmless due to substantial independent evidence of marijuana identity and Doolin’s admission.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether admission of the in-court field test was error for lack of reliability foundation	Doolin argues reliability not established	State relies on Burkett to support admissibility	Yes; admission was error
Whether the error was harmless given other independent evidence	Doolin contends the error contributed to guilt	N/A (not applicable; court analyzes harmlessness)	Harmless error due to substantial other evidence of marijuana identity and admission

West v. State, 805 N.E.2d 909 (Ind. Ct. App. 2004) (admission error when reliability not shown for field test (Daubert framework cited))
Burkett v. State, 691 N.E.2d 1241 (Ind. Ct. App. 1998) (field test admissibility; officer qualifications; reliability not automatic)
Houston v. State, 553 N.E.2d 117 (Ind. 1990) (reliability of field test previously relied on; pre-rule-702 context)
Bellamy v. State, 286 N.E.2d 403 (Ind. 1972) (earlier field-test admissibility cited by Burkett)
Vasquez v. State, 741 N.E.2d 1214 (Ind. 2001) (identity of drug may be established by officer’s experience)
Daubert v. Merrell Dow Pharm., Inc., 509 U.S. 579 (1993) (reliability analysis for scientific evidence)