State v. Patel

CourtSuperior Court of Delaware
DecidedFebruary 26, 2021
Docket1909006286
StatusPublished

This text of State v. Patel (State v. Patel) is published on Counsel Stack Legal Research, covering Superior Court of Delaware primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Patel, (Del. Ct. App. 2021).

Opinion

IN THE SUPERIOR COURT OF THE STATE OF DELAWARE

STATE OF DELAWARE ) ) ) ) v. ) ID NO. 1909006286 ) ALOK PATEL, ) ) )

Decided: February 26, 2021

ORDER

Upon Defendant Alok Patel’s Motion in Limine to Exclude Blood Test Results DENIED.

Jordan A. Braunsberg, Esquire, Department of Justice, Wilmington, Delaware, Attorney for the State of Delaware.

Joseph A. Hurley, Esquire, Law Office of Joseph A. Hurley, Wilmington, Delaware, Attorney for the Defendant.

SCOTT, J. Before the Court is Defendant Alok Patel’s (“Mr. Patel”) Motion in Limine to

exclude his blood test results. For the following reasons, Mr. Patel’s Motion in

Limine is DENIED.

Relevant Facts

On September 11, 2019, an officer of the Newark Police Department, in an

incident involving traffic violations, arrested Mr. Patel and alleged he was driving

under the influence (“DUI”).1 Following his arrest, the Newark Police Department

obtained a blood search warrant.2 Approximately two hours after Mr. Patel was

initially stopped, a phlebotomist from Seascape Health Alliance (“Ms. Allen”)

procured a sample of Mr. Patel’s blood.

On October 27, 2020, after the parties’ second Final Case Review, Mr. Patel

requested the State to share the instructions that accompany the DSP Blood Kit. On

November 2, 2020, the State provided the DSP Blood Kit instructions (the “DSP

Instructions”) and provided a five-page instruction manual (the “Insert”) from the

manufacturer of the blood collection tube that is also included in the DSP Blood

Kit.3

1 State’s Answ. to Def.’s Mot. at ¶ 5. 2 Id. at ¶ 6. 3 Id. at ¶ 2.

1 The DSP Instructions state: “[i]mmediately after blood collection, assure

proper mixing of anticoagulant/preservative powder by slowly and completely

inverting the tube.”4

The Insert states, in pertinent part, that:

For proper additive performance, invert BD SSTTM Tubes or Plus Serum Tubes 5 times. Invert BD CAT Tubes 5-6 times. Invert BD SSTTM II Advance Tubes 6 times. Invert Citrate or CTAD tubes 3-4 times. Invert all other filled additive tubes 8-10 times. […]. Insufficient mixing or delayed mixing in serum tubes may result in delayed clotting and incorrect test results. In tubes with anticoagulants, inadequate mixing may result in platelet clumping, clotting and/or incorrect test results.5

Additionally, the Insert provides a laboratory the authority to develop their

own collection procedures for the testing instruments:

Whenever changing any manufacturer’s blood collection tube types, size, handling, processing, or storage condition for a particular laboratory assay, the laboratory personnel should review the tube manufacturer’s data and their own data to establish/verify the reference range for a specific instrument/reagent system. Based on such information, the laboratory can then decide if a change is appropriate.6

On November 13, 2020, Defendant filed his (1) Motion in Limine to Exclude

Blood Test Results of Defendant (“Motion”) and his (2) Memorandum in Support

of In Limine Motion to Exclude Blood Test Results (“Memorandum”). On

November 30, 2020, the State filed an Answer to Defendant’s Motion in Limine to

Exclude Blood Test Results.

4 Id. at ¶ 7. 5 Id., Ex. B. at p. 4 (Instruction 13) (emphasis added). 6 Id. at p. 4. (emphasis added).

2 Parties Assertions A. The Defendant

In his Motion, Defendant argues that “a sufficient foundation will not be

presented by the State to permit admissibility of the instructions nor will there be

sufficient evidence of appropriate compliance therewith.” As a result, through his

motion, Defendant moves “to exclude the BAC calculation that was measured after

the collection of the Defendant’s blood.”7

In his Memorandum, Defendant clarifies his argument and states that

“[h]istorically, upon information and belief, the same manufacturer has required a

complete inversion of the collection tube no fewer than five times, post collection,

in order to bring into play the forces of gravity to assure proper distributions” and

“[t]he version anticipated to be proffered by the State offers no guidance,

quantitatively.”8 Moreover, the Defendant argues that “the testimony of the State

Chemist that proper distribution can be obtained by whatever method she advocates

is not a substitute, since she has no background in calibrating that particular phase

of collection albeit much experience in the laboratory analysis of the product,

whatever its constitution, that is tested.”9

7 Def.’s Mot. in Limine “to Exclude Blood Test Results of the Defendant” at p. 2. 8 Def.’s Mem. In Supp. of In Limine Motion to Exclude Blood Test Results at p. 2. 9 Id.

3 As a result, Defendant moves “to exclude the written manufacturer’s

instruction and/or the ultimate test results based upon a failure to comply with DRE

702 in presenting, by a preponderance of the evidence, the reliable marker to guide

the collection process.”10

Defendant argues that the Insert, not the DSP Instructions, set the foundational

requirements for entering Defendant’s blood test results (“BAC Results”) into

evidence. Additionally, Defendant argues that the State Chemist’s testimony is not

sufficient because she has no background in the collection of blood. 11 As a result,

Defendant moves to exclude the Insert and Defendant’s BAC Results based on the

State’s inability to comply with Delaware Rule of Evidence 702 in presenting the

State’s compliance with collection of Defendant’s blood.

B. The State

The State disagrees that the Insert sets the foundational requirements for entry

of Defendant’s BAC Results. The State claims that they only need to show

compliance with the DSP Instructions.12 However, even if compliance with the Insert

is the proper foundational requirement, the State argues that they have complied with

the Insert because the Insert provides authority for a lab to establish its own

10 Id. at pp. 2-3. 11 Id. at p. 2. 12 State’s Answ. to Def.’s Mot. at ¶ 12.

4 protocols.13 The State asserts that the DSP Instructions are authorized by Julie Willey

(“Director Willey”), the Director of the Delaware State Police Crime Lab

(“DSPCL”).14 Director Willey’s role as Directors of the DSPCL is to “oversee the

blood and breath DUI program and to also personally perform headspace gas

chromatograph testing,” (“HSGC”) which includes the testing of the Defendant’s

blood in the instant matter.15

Moreover, the State argues that, even if the preservative failed to mix

properly, the failure to properly mix the preservative does not prejudice the

Defendant because it would actually lower the final BAC level.16

Finally, regarding expert testimony, the State contends that Ms. Allen will

testify about the collection process and that she inverted the tube “2-3 times.”17

Standard of Review

“A motion in limine typically concerns the admissibility of evidence and is a

preliminary motion directed at establishing the ‘ground rules applicable at trial.’”18

“The admissibility of intoxilyzer test results center on the State providing an

13 Id. 14 Id. at ¶ 7. 15 Id. (see fn. 6). 16 Id. at ¶ 21. 17 Id. at ¶ 6. 18 Hercules, Inc. v. AIU Ins. Co., 784 A.2d 481, 500 (citing to 3 Moore's Federal Practice § 16.77[4][d] (3d ed.1997)).

5 adequate evidentiary foundation for the test result’s admission.”19 Compliance with

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Bluebook (online)
State v. Patel, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-patel-delsuperct-2021.