375 P.3d 279
Idaho2016Background
- In Oct. 2013 police arrested Kentsler Lee Jones for driving the wrong way and suspected intoxication; a hospital blood draw produced a result of 0.207 with a reported measurement of uncertainty ±0.0103.
- State charged Jones with felony DUI under I.C. § 18-8004C(2) (prior DUI with BAC ≥ 0.20) and a misdemeanor resisting/obstructing charge (later dismissed).
- State moved in limine to exclude any evidence about the measurement of uncertainty; the district court granted the motion and denied reconsideration, citing Elias-Cruz.
- Jones entered a conditional guilty plea to preserve appeal of the exclusion ruling; the district court sentenced him to a suspended unified term and placed him on probation.
- On appeal Jones argued (1) Elias-Cruz was wrongly decided and should be overruled because DUI statutes criminalize actual BAC, not merely test results, and (2) exclusion of uncertainty evidence violated his right to present a complete defense.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Admissibility of measurement of uncertainty tied to actual BAC | State: measurement of uncertainty is irrelevant under current statute and Elias-Cruz; test result controls | Jones: uncertainty shows actual BAC could be below statutory threshold, so it is relevant | Court: Exclusion affirmed; under Elias-Cruz the statutory standard is the test result, not the person’s "actual" BAC, so the uncertainty about actual BAC is irrelevant |
| Whether Elias-Cruz should be overruled | State: Elias-Cruz remains controlling precedent; not manifestly wrong | Jones: Elias-Cruz misreads I.C. § 18-8004(4) and undermines statute’s focus on actual BAC | Court: Declined to overturn Elias-Cruz; stare decisis applies |
| Constitutional right to present a complete defense | State: exclusion of irrelevant evidence does not violate due process | Jones: exclusion prevented him from presenting evidence that could negate felony element | Court: No constitutional violation; defendants may not present irrelevant evidence |
| Relevance of measurement of uncertainty as part of test result completeness | State: Jones did not argue that uncertainty is integral to the validity of the test result | Jones: did not press this specific theory on appeal | Court: Not decided; acknowledged scientific distinction between uncertainty and machine error and reserved the issue for cases raising it |
Key Cases Cited
- Elias-Cruz v. Idaho Dep’t of Transp., 153 Idaho 200 (2012) (holding statutory BAC standard is the concentration shown by an approved test, not the person’s "actual" blood alcohol concentration)
- State v. Owens, 158 Idaho 1 (2015) (discussing stare decisis limits on overruling precedent)
- Crane v. Kentucky, 476 U.S. 683 (1986) (right to present a complete defense requires a meaningful opportunity to present evidence)
- State v. Hoisington, 104 Idaho 153 (1983) (court will not decide issues not raised by the parties)
- Dulaney v. St. Alphonsus Reg’l Med. Ctr., 137 Idaho 160 (2002) (standard for appellate review of evidentiary rulings)