State v. Guerra, 497 P.3d 1106

Background

Guerra was stopped after an officer observed her driving with a cigarette and phone; she showed glassy eyes, confused speech, poor balance, and performed poorly on field sobriety tests; breath test was negative for alcohol.
Officer DeLeon (certified DRE and phlebotomist) conducted a drug recognition evaluation, concluded Guerra was under the influence of CNS depressants, drew blood, and lab tests detected several drugs that can impair driving.
Guerra was charged with DUI (Idaho Code § 18-8004(1)(a)) with a sentencing enhancement for a prior DUI; discovery disputes arose when the State belatedly disclosed (a) DeLeon’s 2019 phlebotomy recertification and (b) a certified prior-judgment showing the earlier DUI.
At trial the magistrate admitted blood-related evidence (over Guerra’s motion in limine challenging DeLeon’s qualification under § 18-8003) and allowed DeLeon to testify about warnings on prescription bottles; the jury convicted Guerra and the magistrate imposed sentence (suspended jail, probation).
On intermediate appeal the district court affirmed; the Idaho Supreme Court affirmed most rulings but reversed the admission of DeLeon’s testimony about a motor-vehicle warning on the pill bottles as inadmissible hearsay, held the error was not harmless, vacated the judgment, and remanded for further proceedings.

Issues

Issue	Plaintiff's Argument	Defendant's Argument	Held
Sufficiency of evidence (I.C.R. 29) / new trial (I.C.R. 34)	Totality of evidence (observations, field tests, DRE opinion, blood tox) proved DUI beyond a reasonable doubt	Evidence did not establish impairment caused by drugs; conviction unsupported	Affirmed: viewing evidence in State's favor, a rational juror could find guilt; Rule 34 claim not argued and waived
Late disclosure: DeLeon’s 2019 phlebotomy requalification	Certificate is cumulative corroboration of his qualification; no prejudice	Late disclosure prejudiced preparation; sanctions warranted	Affirmed: trial court acted within discretion; no prejudice shown; admission harmless/cumulative
Late disclosure: certified prior-judgment for enhancement	State only recently received certified copy; defendant was on notice from charging documents	Late production prevented defense investigation and preparation	Affirmed: no cognizable prejudice; admission within trial court’s discretion
Officer qualification to draw blood (§ 18-8003)	DeLeon trained and employer (Caldwell PD) designated ISP blood-draw standards; met statutory definition of phlebotomist	No written departmental policy shown; thus officer not authorized under statute	Affirmed: record support that DeLeon met statutory standards and magistrate did not abuse discretion
Admission of testimony about pill-bottle motor-vehicle warning (hearsay)	Offered to show existence/effect of warnings (non-hearsay purpose) or to show defendant’s knowledge; also cumulative of other evidence	Testimony was hearsay and used for truth (that medication impairs driving); highly probative on causation	Reversed in part: testimony about motor-vehicle warning was hearsay, no proper non-hearsay purpose, error not harmless; conviction vacated and remanded

Key Cases Cited

State v. Abdullah, 158 Idaho 386 (2015) (standard for reviewing denial of judgment of acquittal: view evidence in light most favorable to prosecution)
State v. Stark, 157 Idaho 29 (Ct. App. 2013) (blood metabolite evidence that does not show intoxicating substance may be insufficient to prove causation of impairment)
State v. Garcia, 166 Idaho 661 (2020) (adopted Yates two-part harmless-error balancing for nonconstitutional errors)
State v. Montgomery, 163 Idaho 40 (2017) (defendant must show error occurred; then State must prove error harmless beyond a reasonable doubt)
State v. Robinett, 141 Idaho 110 (2005) (DUI may be proved under the totality of the evidence)
State v. Clark, 161 Idaho 372 (2016) (I.C.R. 29 sufficiency framework)