State v. Sneva, C

Decision Date24 August 1984
Docket NumberNo. C,C
PartiesSTATE of Minnesota, Respondent, v. Timothy J. SNEVA, Appellant. x-83-215.
CourtMinnesota Supreme Court

Syllabus by the Court

In trial of defendant for criminal negligence resulting in death, Minn.Stat. Sec. 609.21 (1982), trial court did not abuse its discretion in overruling foundational objections to evidence as to defendant's blood alcohol concentration and as to expert testimony concerning the effects of alcohol on a driver.

Philip G. Villaume, Terry L. Hegna, St. Paul, for appellant.

Hubert H. Humphrey, III, Atty. Gen., St. Paul, Tom Foley, Ramsey County Atty., Steven C. DeCoster, Asst. County Atty., St. Paul, for respondent.

Considered and decided by the court en banc without oral argument.

TODD, Justice.

Defendant was found guilty by a district court jury of a charge of criminal negligence resulting in death, Minn.Stat. Sec. 609.21 (1982). 1 The trial court sentenced defendant to an 18-month prison term but stayed execution of the sentence and placed defendant on probation for 5 years, subject to a number of conditions, including that defendant serve 6 months in the workhouse. The trial court stayed execution of the workhouse term pending this appeal. On appeal, defendant does not challenge the sufficiency of the evidence. Instead, he argues that he was denied a fair trial by the admission of testimony that he had a blood alcohol concentration of .14 and by the admission of expert testimony concerning the effects of alcohol on a driver. Specifically, defendant contends that the state did not establish that the blood tested was his, that the blood was properly drawn and preserved, or that the expert was qualified to testify concerning the effects of alcohol on a driver. Our examination of the record satisfies us that the trial court did not abuse its discretion in overruling the foundational objections to the admissibility of this evidence. Minn.R.Evid. 104, 702, and 901; State v. Williams, 337 N.W.2d 689 (Minn.1983); State v. Hager, 325 N.W.2d 43 (Minn.1982); State v. Dille, 258 N.W.2d 565 (Minn.1977); State v. Anderson, 302 Minn. 77, 223 N.W.2d 789 (1974).

Affirmed.

1 At the time that defendant violated the statute stated basically that anyone who operates a motor vehicle in a grossly negligent manner and thereby causes the death of a human being is guilty of criminal negligence resulting in death. The subsequently-amended statute now provides that anyone who operates a motor vehicle either...

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3 cases
  • State v. Caulfield, No. A04-1484.
    • United States
    • Minnesota Supreme Court
    • October 5, 2006
    ...Fields, 679 N.W.2d 341, 345 (Minn.2004); Lindberg v. Comm'r of Pub. Safety, 498 N.W.2d 301, 303 (Minn.App. 1993) (citing State v. Sneva, 353 N.W.2d 134, 134 (Minn.1984)). But whether the admission of evidence violates a criminal defendant's rights under the Confrontation Clause is a questio......
  • Lindberg v. Commissioner of Public Safety, C5-92-1604
    • United States
    • Minnesota Court of Appeals
    • April 6, 1993
    ...(Minn.App.1990). Rulings on the admissibility of evidence are not overturned absent a showing of abuse of discretion. State v. Sneva, 353 N.W.2d 134, 134 (Minn.1984). The proponent of a chemical or scientific test must establish that the test itself is reliable and that its administration i......
  • State v. Eli
    • United States
    • Minnesota Court of Appeals
    • March 24, 1987
    ...blood sample was a foundational objection that should have been raised at the time the test results were introduced. See State v. Sneva, 353 N.W.2d 134 (Minn.1984). Because this alleged error does not constitute plain error or an error of fundamental law, defense counsel's failure to object......

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