Randy Campbell v. the People of the State of Colorado

Summary

The court held that the officer's testimony about administering and interpreting the HGN test was expert testimony because it depended on specialized training, knowledge, and experience, and therefore was improperly admitted as lay testimony. The court nevertheless affirmed because the preserved, nonconstitutional evidentiary error was harmless in light of the overwhelming independent evidence that Campbell drove while impaired. The court affirmed the district court's judgment.