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State v. Davis

Hawaii Supreme Court
140 Haw. 252 (2017)


Facts

Raymond Davis (defendant) was charged with operating a vehicle while intoxicated. At Davis’s trial, the State of Hawaii (plaintiff) introduced into evidence a machine operator’s sworn out-of-court statement that the Intoxilyzer machine used to test Davis’s breath-alcohol content was working properly. The state used the statement to establish that the results of Davis’s breath-alcohol test were reliable. The state sought to admit the statement under both the public-records exception and the business-records exception to the hearsay rule. The trial court admitted the statement under the public-records exception. Davis was convicted, and the appellate court affirmed the conviction. Davis appealed to the Hawaii Supreme Court.

Rule of Law

Issue

Holding and Reasoning (Pollack, J.)

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