Utah Court of Appeals
Can conflicting blood test results support a DUI conviction? State v. Spencer Explained
Summary
Spencer was convicted of DUI after a blood test showed .08 blood alcohol concentration. He had an independent laboratory retest his blood sample, which showed .079, below the legal limit. The district court convicted Spencer after finding the difference between test results was not statistically significant.
Practice Areas & Topics
Analysis
In State v. Spencer, the Utah Court of Appeals addressed whether conflicting blood alcohol test results can support a DUI conviction when one test shows results above the legal limit and another shows results below.
Background and Facts
During a traffic stop in August 2018, a deputy detected a strong alcohol odor from Spencer’s vehicle and found open containers of alcohol. After arresting Spencer for suspected DUI, a warranted blood draw was conducted. The Utah Public Health Laboratory tested Spencer’s blood and reported a result of .08 grams of ethanol per 100 milliliters of blood, meeting the legal threshold for per se DUI. Spencer subsequently had his blood independently tested by a Colorado laboratory, which reported .079, below the legal limit. At his bench trial, Spencer was convicted of DUI despite presenting the Colorado test results.
Key Legal Issues
The central issue was whether sufficient evidence supported Spencer’s DUI conviction when two valid blood tests produced conflicting results. Spencer argued the conflicting test results created reasonable doubt about whether his blood alcohol concentration exceeded the legal limit.
Court’s Analysis and Holding
The Court of Appeals applied the clear error standard to Spencer’s insufficient evidence claim from his bench trial. The court emphasized that weighing conflicting evidence is exclusively the factfinder’s role. Importantly, Spencer’s own expert testified that the difference between .079 and .08 was not statistically significant and that the Colorado results confirmed the State’s results “within their measurement of uncertainty.” The court held that Spencer failed to invalidate the State’s test results and merely presented alternative evidence for the factfinder to weigh.
Practice Implications
This decision underscores that presenting contradictory test results alone is insufficient to overturn a DUI conviction. Defense counsel must present evidence that actually invalidates the State’s testing methodology or results, rather than simply offering alternative test results. The ruling also highlights the importance of expert testimony – here, Spencer’s own expert undermined his defense by confirming the statistical validity of both test results.
Case Details
Case Name
State v. Spencer
Citation
2025 UT App 66
Court
Utah Court of Appeals
Case Number
No. 20230863-CA
Date Decided
May 8, 2025
Outcome
Affirmed
Holding
When two valid blood alcohol tests produce conflicting results, the factfinder may weigh the evidence and accept the test result that places the defendant’s blood alcohol concentration above the legal limit for DUI conviction.
Standard of Review
Clear error for claims of insufficient evidence at bench trial
Practice Tip
When challenging blood test results in DUI cases, present evidence that actually invalidates the State’s test rather than merely offering contradictory results, as factfinders may weigh conflicting valid evidence.
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