Idaho v. Hill
Annotate this CaseJonathan Hill was convicted for felony driving under the influence (DUI). He raised one issue on appeal. Over an unsuccessful hearsay objection, the deputy sheriff who conducted field sobriety tests (FSTs) of Hill was permitted to testify as to what he had been taught regarding the presence of vertical nystagmus. Hill’s appeal challenged that evidentiary ruling. The Supreme Court found that even if the testimony was relied upon for the basis of an expert opinion, it was improper to disclose the facts upon which Deputy Smith based his opinion. This error was not harmless, and as such, the Supreme Court vacated Hill's conviction and remanded the matter for a new trial.
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