State v. Austin White

2023 VT 38, 307 A.3d 872
CourtSupreme Court of Vermont
DecidedJuly 7, 2023
Docket22-AP-216
StatusPublished

This text of 2023 VT 38 (State v. Austin White) is published on Counsel Stack Legal Research, covering Supreme Court of Vermont primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Austin White, 2023 VT 38, 307 A.3d 872 (Vt. 2023).

Opinion

NOTICE: This opinion is subject to motions for reargument under V.R.A.P. 40 as well as formal revision before publication in the Vermont Reports. Readers are requested to notify the Reporter of Decisions by email at: JUD.Reporter@vermont.gov or by mail at: Vermont Supreme Court, 109 State Street, Montpelier, Vermont 05609-0801, of any errors in order that corrections may be made before this opinion goes to press.

2023 VT 38

No. 22-AP-216

State of Vermont Supreme Court

On Appeal from v. Superior Court, Caledonia Unit, Civil Division

Austin White April Term, 2023

Justin P. Jiron, J.

Claire E. Burns, Caledonia County Deputy State’s Attorney, St. Johnsbury, for Plaintiff-Appellee.

David C. Sleigh of Sleigh Law, PC, St. Johnsbury, for Defendant-Appellant.

PRESENT: Reiber, C.J., Eaton, Carroll, Cohen and Waples, JJ.

¶ 1. COHEN, J. Defendant appeals from the civil division’s final judgment

suspending his driver’s license. He argues that the trial court abused its discretion in admitting the

results of an evidentiary blood-alcohol test because the State did not offer sufficient evidence to

demonstrate that defendant’s blood sample was collected and analyzed in compliance with

Department of Public Safety (DPS) rules. We conclude that there was an insufficient foundation

to allow admission of the test result and therefore reverse and remand for entry of judgment for

defendant.

¶ 2. In October 2020, defendant drove his truck off a road in St. Johnsbury, Vermont.

The state trooper who arrived at the scene developed reason to believe defendant was impaired by alcohol. Defendant was treated at Northern Vermont Regional Hospital, and there consented to

the withdrawal of a blood sample for alcohol testing.1

¶ 3. The Vermont Forensics Laboratory (VFL) analyzed the blood specimen for alcohol

content and determined the blood-alcohol content (BAC) to be 0.106 percent at the time of

collection. After receiving the VFL report, the trooper served defendant with notice that the

Department of Motor Vehicles would suspend his driver’s license unless he requested a hearing to

contest the allegation by a certain date. Defendant timely requested a hearing and filed a notice of

contested issues, including, as relevant here, whether the test was taken and analyzed in

compliance with DPS rules.

¶ 4. A final merits hearing was conducted in August 2022. The State’s evidence was

limited to two exhibits. Exhibit 1 was a template affidavit completed by the responding trooper,

including his observations and narration of the incident. Exhibit 1 also included an unsworn,

signed report from the VFL summarizing the results of its analysis of defendant’s blood sample,

addressed to the state police barracks. Exhibit 2 was an affidavit of a VFL chemist, providing her

assumptions, inputs, and relation-back analysis of defendant’s blood sample.

¶ 5. Defendant raised various objections to admission of the exhibits and to the blood-

test result based on an alleged lack of foundation in these exhibits. As relevant here, defendant’s

counsel argued essentially that the trooper’s only reference to the DPS rules was his affirmation

that “[t]he sample was obtained pursuant to the Vermont Department of Public Safety rules,” and

that this was inadequate to demonstrate that the blood test complied with all the applicable DPS

1 We note that “Vermont law regarding DUI explicitly favors breath testing over blood testing.” State v. Giguere, 2017 VT 40, ¶ 8, 204 Vt. 483, 169 A.3d 778. However, blood testing is appropriate “[i]f breath testing equipment is not reasonably available or if the officer has reason to believe that the person is unable to give a sufficient sample of breath for testing or if the law enforcement officer has reasonable grounds to believe that the person is under the influence of a drug other than alcohol.” 23 V.S.A. § 1202(a)(2). Here the trial court found that blood testing was lawful under the circumstances, and defendant does not challenge that determination on appeal, so we do not address it. 2 rules and therefore could not provide a foundation for admission of the blood-test result. Counsel

explained:

[W]e object to the conclusory statement at the top of page 4 of the same affidavit. The statement purports that the blood sample was obtained pursuant to the Vermont Department of Public Safety Rules, but there’s no evidence to support that assertion made by the trooper. The affidavit doesn’t explain or express which particular rules were complied with or demonstrate how those rules were complied with, or even demonstrate how the trooper knew that these rules were complied with.

Additionally, there’s no affidavit or statement from the nurse who obtained this blood sample, describing how that nurse obtained the sample and how that collection process was in compliance with the rules of the Vermont Department of Public Safety. Therefore, the State could not prove that the sample was, in fact, collected in compliance with the rules beyond the officer’s statement that they were. That is very much unsupported by his affidavit.

¶ 6. The court overruled the objection, reasoning that the plain terms of 23 V.S.A.

§ 1203(d) do not require anything more than a “conclusory” statement of compliance with DPS

rules. Similarly, defendant’s counsel objected that the VFL report’s only reference to DPS—that

“[a]nalysis of the sample for ethanol was performed by gas chromatography, a method approved

by the Commissioner of Public Safety for this purpose”—was conclusory and insufficient to

demonstrate compliance with the rules. The court again overruled the objection:

Well, it’s sort of like the other rule we talked about, whether under the statute indicating that if there’s evidence that the—a test was taken or analyzed—in this case, analyzed in compliance with rules adopted by Department of Public Safety, whether that statement at the bottom of—or partway down under the analysis summary saying that it was performed by gas chromatography, a method approved by the commissioner of public safety complies with the statute. I mean, it does reference the commissioner of public safety and the method approved by the commissioner of public safety. So it doesn’t actually specifically talk about the rules, but I do find that it does present some evidence that it was—that the method was used, according to the commissioner of public safety’s rules.

3 The court admitted the blood-alcohol test results, found that the State had proved the requirements

under 23 V.S.A. § 1205 for a civil license suspension by a preponderance of evidence, and

ultimately entered judgment in the State’s favor.

¶ 7. On appeal, defendant argues that the court erred in admitting the test results because

the State failed to provide the requisite foundation for admissibility—that the blood-sample

analysis was performed in compliance with all applicable DPS rules. In general, we review

evidentiary rulings for abuse of discretion. State v. Eldert, 2015 VT 87, ¶ 14, 199 Vt. 520, 125

A.3d 139. We note, however, that in civil-suspension proceedings the Rules of Evidence are not

applied strictly. V.R.C.P. 80.5(f)(3) (“Evidence is admissible if it is of a type commonly relied

upon by reasonably prudent persons in the conduct of their affairs, and the Vermont Rules of

Evidence are inapplicable except for the rules respecting privilege.”).

¶ 8. To obtain a judgment against defendant, the State was required to prove the

elements set forth in 23 V.S.A. § 1205(h)(1)(A)-(E) by a preponderance of evidence. See 23

V.S.A.

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Related

State v. Rolfe
686 A.2d 949 (Supreme Court of Vermont, 1996)
State v. Massey
730 A.2d 623 (Supreme Court of Vermont, 1999)
State v. Eldert
199 Vt. 520 (Supreme Court of Vermont, 2015)
State v. Renee P. Giguere
2017 VT 40 (Supreme Court of Vermont, 2017)
State v. Burnett
2013 VT 113 (Supreme Court of Vermont, 2013)
State v. Eldert
2015 VT 87 (Supreme Court of Vermont, 2015)

Cite This Page — Counsel Stack

Bluebook (online)
2023 VT 38, 307 A.3d 872, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-austin-white-vt-2023.