State of New Jersey, Plaintiff-Appellant v. Peter Dyal, Defendant-Respondent

Summary

The Court held that the patient‑physician privilege does not bar admission of a blood‑test result when police obtain the record by a subpoena after showing a reasonable basis to believe the driver was intoxicated, and it found the prosecutor's reference to the .10% legal threshold to be harmless error. The judgment of the Appellate Division was affirmed as modified and the case was remanded for a hearing on admissibility.