People v. Crump, 118 N.E.3d 608

In May 2015 Xavier Crump was arrested after a trooper found him asleep in a vehicle; trooper observed signs of alcohol use and administered field sobriety tests and an Intoxilyzer breath test.
The breath printout and logbook showed a BAC of 0.131 (printout’s third decimal was partially redacted).
The State introduced, over defense objection, an electronic "verified certification" (Keeper of Records letter with attachments) showing accuracy checks of the Intox EC/IR-II on May 1 and June 5, 2015, with notations “System Check: Passed” and “Test Status: Success,” and a logbook entry by Trooper Sheldon certifying accuracy on June 5.
The trial court convicted Crump of driving with an alcohol concentration of 0.08 or more and improper parking, but acquitted him of DUI (625 ILCS 5/11-501(a)(2)); sentence included supervision and fines.
On appeal Crump argued (1) the State failed to lay a proper foundation to admit the electronic certification as a business record and (2) even if admitted, the records did not establish the machine was properly tested and accurate on the test date.
The Third District affirmed: the electronic certification was admissible as a self-authenticating business record and the certification attachments (showing “passed”/“success” notations and logbook entry) satisfied the regulatory foundational requirement that the machine was tested and working properly within the applicable time frame.

Issue	State's Argument	Crump's Argument	Held
Whether the electronic "verified certification" (certification attachments) was admissible as a business record/self-authenticating document	The certification bore the ISP seal, was signed by Keeper of Records, recited the three Rule 902(11)/803(6) foundations, and so is self-authenticating	State failed to lay foundation; records untrustworthy because attachments lack identifying author info, logbook lacked May 1 entry, printout redacted third digit	Admissible. Court found certification met Rule 902(11) requirements and trial court did not abuse discretion admitting it
Whether the State proved the breath machine was tested and working properly on the test date (Orth foundational requirement regarding accuracy checks)	The certification attachments show accuracy checks within the required period with clear notations “System Check: Passed” and “Test Status: Success,” and the logbook contains a June 5 certified-accurate entry, satisfying regulatory requirements	Records insufficient—comparing to Smith, raw data without interpretation doesn’t show machine passed tolerance; Crump argued no certification that machine was accurate within 62 days	Held for State. Court distinguished Smith and found the attachments contained pass/success notations and a logbook certification, satisfying the regulation and Orth foundational requirement

People v. Orth, 124 Ill.2d 326 (establishes foundational requirements for admission of breath test results)
People v. Donoho, 204 Ill.2d 159 (standard for abuse of discretion review)
People v. Claudio, 371 Ill. App.3d 1067 (discusses standard for reviewing foundational requirements for breath-test evidence)