People v. Malone, 16 N.Y.2d 196 (1965)
Results of a blood test are admissible as evidence in court if a proper chain of identification is established, linking the defendant to the unadulterated fluid examined by a qualified person.
Summary
The New York Court of Appeals considered the admissibility of blood test results in a case where the defendant was convicted of operating a motor vehicle while intoxicated. The County Court reversed the conviction, citing concerns about the qualifications of the blood test administrator and the possibility of contamination. The Court of Appeals reversed the County Court’s decision, holding that the blood test results were admissible because a proper chain of identification had been established, linking the defendant to the unadulterated blood sample examined by a qualified chemist. The court emphasized that the evidence sufficiently demonstrated that the tested fluid was indeed the defendant’s blood and that it had not been tampered with.
Facts
The defendant was arrested for operating a motor vehicle while intoxicated. A doctor took a blood sample from the defendant after allegedly instructing a nurse to use a nonalcoholic solution to sterilize the defendant’s arm. The doctor placed the sample in a vial, sealed it, and prepared it for mailing. A State Trooper took possession of the sample, locking it in a secure strongbox. The next day, the trooper mailed the sample via certified mail to the State Police Laboratory in Albany. A chemist at the lab tested the sample and found it to contain .02% alcohol over the legal limit for intoxication.
Procedural History
The trial court admitted the blood test results as evidence, and the jury convicted the defendant. The County Court reversed the conviction, finding that the blood test results were improperly admitted. The People appealed to the New York Court of Appeals.
Issue(s)
Whether the results of a blood test are admissible in evidence when a proper chain of identification linking the defendant with the unadulterated fluid examined by a qualified person has been established.
Holding
Yes, because ample proof showed the liquid tested at the laboratory was the same as that taken from the arm of the defendant; thus, the results of the blood test were competent and properly admitted into evidence.
Court’s Reasoning
The Court of Appeals reasoned that the key factor in determining the admissibility of the blood test results was whether a proper chain of identification had been established. The court found that the testimony of the doctor, the State Trooper, and the chemist sufficiently established this chain. The doctor testified that he believed a nonalcoholic solution was used to sterilize the defendant’s arm. The State Trooper testified that he secured the sample and mailed it to the lab without it being accessible to others. The chemist was qualified and performed the test.
The court rejected the County Court’s concerns that the sample might not have been blood or that it might have been contaminated by an alcoholic antiseptic. The court stated, “Since there was ample proof that the liquid tested at the laboratory was the same as that taken from the arm of the defendant, it was not necessary to conduct an additional test to ascertain whether the sample was blood.” The court found that the testimony was sufficiently positive to allow the jury to find that a nonalcoholic preparation was used.
The court also noted that the County Court’s order did not state whether its determination was based on law or facts. Therefore, the Court of Appeals reversed the County Court’s order and remitted the case for a proper determination of the questions of fact.