State v. Edstrom
2010 Minn. App. LEXIS 181
Minn. Ct. App.2010Background
- Edstrom was arrested May 3, 2009 for DWI after a urine test reported .08 alcohol by the BCA.
- Edstrom requested a Frye-Mack hearing on first-void urine testing and moved to suppress the urine result.
- The district court held a Frye-Mack hearing and admitted expert testimony but suppressed the urine result, dismissing count two.
- The court allowed count one (DWI) to proceed based on other impairment evidence.
- The state appealed the pretrial rulings challenging the Frye-Mack hearing, the expert testimony, and the exclusion of the urine result.
- The court affirmed in part, reversed in part, and remanded for further proceedings.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a Frye-Mack hearing was required for gas headspace chromatography. | State contends technique is not novel; already accepted. | Edstrom argues no Minnesota ruling evaluating it under Frye-Mack. | Frye-Mack hearing proper; technique merits evaluation. |
| Whether admitting expert testimony on gas headspace chromatography was an abuse of discretion. | State needed testimony to support Frye-Mack hearing. | Edstrom argues testimony should be excluded. | No abuse of discretion; testimony proper for hearing. |
| Whether gas headspace chromatography satisfies Frye-Mack for urine samples (first-void or later void). | State relies on general acceptance. | Edstrom challenges reliability for first-void samples. | Gas headspace chromatography satisfies Frye-Mack for urine tests. |
| Whether excluding the urine test result was an abuse of discretion and whether count two should be dismissed. | Urine result is probative and not unfairly prejudicial. | Exclusion prevents jury from understanding impairment evidence. | Trial court abused discretion by excluding the result and dismissing count two. |
Key Cases Cited
- State v. Jobe, 486 N.W.2d 407 (Minn. 1992) (establishes Frye-Mack framework for scientific evidence)
- State v. Roman Nose, 649 N.W.2d 815 (Minn. 2002) (remands for Frye-Mack on novel techniques; focus on reliability)
- Hayes v. Comm’r of Pub. Safety, 773 N.W.2d 134 (Minn.App. 2009) (first-void urine testing considered in implied-consent)
- Genung v. Comm’r of Pub. Safety, 589 N.W.2d 311 (Minn.App. 1999) (validity of first-void urine testing in implied-consent context)
- City of Springfield v. Anderson, 411 N.W.2d 292 (Minn.App. 1987) (exclusion of experts on first-void testing was not abuse)