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State v. St. Amant

Louisiana Court of Appeal
504 So. 2d 1094 (1987)
ELI5:

Rule of Law:

To admit the results of a chemical breath test to prove intoxication, the state bears the burden of proving it strictly complied with all officially promulgated methods and procedures designed to ensure the test's reliability.


Facts:

  • Officer Robert Bourgeois stopped a car driven by Eva St. Amant after it matched the description given in a harassment complaint.
  • Upon St. Amant exiting the vehicle, Officer Bourgeois observed that she was unsteady on her feet, seemed confused, and smelled of alcohol.
  • Officer Bourgeois arrested St. Amant on suspicion of DWI and transported her to the Jefferson Parish Correctional Center.
  • At the correctional center, Sergeant J.E. Montville administered a breath analysis test to St. Amant using an Intoxilyzer 5000 machine.
  • St. Amant also performed a field sobriety test which was recorded on videotape.

Procedural Posture:

  • The State of Louisiana charged Eva C. St. Amant with operating a vehicle while intoxicated (DWI), second offense, in the trial court.
  • After a bench trial, the trial court found St. Amant guilty as charged.
  • St. Amant (appellant) sought review of her conviction from the Court of Appeal of Louisiana, Fifth Circuit, which agreed to treat her appeal as an application for a supervisory writ.

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Issue:

Does the State's failure to present evidence that the officer used a clean, new mouthpiece when administering a breathalyzer test, as required by official procedure, render the test results inadmissible in a DWI prosecution?


Opinions:

Majority - Chehardy, Chief Judge

Yes. The State's failure to prove compliance with the required procedure of using a new, clean mouthpiece renders the breathalyzer test results inadmissible. To use the statutory presumption of intoxication arising from a chemical test, the prosecution must demonstrate strict compliance with officially promulgated procedures intended to ensure the test's integrity and reliability, as established in precedents like State v. Gregory. While the court found the required 15-minute observation period was satisfied by St. Amant being in police custody, the State presented no evidence whatsoever that the officer used a new, clean mouthpiece as required by Department of Public Safety rules. This failure is a lapse in the State's burden of proof because a contaminated mouthpiece could significantly impact the validity of the test results. With the intoxilyzer evidence excluded, the remaining evidence—an officer's testimony contradicted by a videotape on which the defendant performed adequately—was insufficient to prove guilt beyond a reasonable doubt.



Analysis:

This decision reinforces the strict compliance standard for the admission of scientific evidence in criminal cases, particularly DWI chemical tests. It establishes that the burden is squarely on the State to affirmatively prove every element of the procedural foundation; courts will not assume compliance. The case demonstrates that a seemingly minor procedural omission, such as failing to testify about using a clean mouthpiece, can be fatal to the admissibility of key scientific evidence and, consequently, the entire prosecution. It serves as a crucial precedent for defense attorneys challenging the foundation of chemical tests and as a warning to prosecutors about the need for meticulous evidence presentation.

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