State v. Buehler
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The case revolves around Cyrus Wolf Buehler, who was convicted for aggravated driving under the influence (DUI) after a collision with a motorized bicycle, resulting in severe injuries to the cyclist, Raymond Hanson. Buehler was found to have a blood alcohol concentration (BAC) of .181 and .179 at the time of the incident. He sought to introduce evidence suggesting that Hanson's conduct was a superseding, intervening cause of the collision, arguing that Hanson was speeding, under the influence, and his bicycle lacked a headlight. Buehler also challenged the admissibility of his BAC results, as the officer who administered the test had an expired certification.
The District Court of the Sixth Judicial District of the State of Idaho denied Buehler's motions, ruling that the evidence he sought to introduce was irrelevant to the determination of whether his act of driving under the influence had some causal connection to Hanson’s injuries. The court also held that the officer’s lapsed certification did not require exclusion of Buehler's BAC results, as the State could establish the foundation for the admission of the evidence through expert testimony. Buehler's conviction was affirmed.
On appeal, the Supreme Court of the State of Idaho upheld the lower court's decision. The Supreme Court held that Hanson's conduct was not relevant to the determination of whether Buehler's act of driving while under the influence had some causal connection to Hanson’s injuries. The court also affirmed the lower court's decision to admit Buehler's BAC results, ruling that the officer's lapsed certification did not affect the validity of the BAC results. The court concluded that the district court did not err in its rulings, and Buehler's judgment of conviction was affirmed.
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