Supreme Court of Delaware

Davis v. State

January 23, 2019

Summary

The Court affirmed the judgment admitting the blood-alcohol certificate and report in Davis’s driving-under-the-influence prosecution. It held that the State established an adequate foundation by presenting evidence that the blood was drawn using normal procedures, and that the phlebotomist’s failure to describe one specific procedural step did not require exclusion absent contrary evidence. The Court found no abuse of discretion in the Superior Court’s evidentiary ruling.