Pennsylvania DUI Lawyers Blog
In DUI cases, courts often rely on evidence from medical records, including blood alcohol content (BAC) results, to support convictions. Recently, a Pennsylvania court affirmed a trial court’s decision to admit BAC evidence from a defendant’s medical records despite the defendant’s challenge based on hearsay and confrontation rights. If you are accused of a DUI crime, it is prudent to meet with a Pennsylvania DUI defense attorney to understand your rights and defenses.
Factual Setting and Procedural History
It is reported that the defendant was involved in a serious vehicle collision after drinking at a local bar and subsequently making an unsafe left turn, resulting in a collision with another vehicle. Allegedly, this accident led to substantial injuries for a passenger in the other car, who required multiple surgeries and extensive rehabilitation. The defendant was transported to a local hospital for treatment, where blood samples were collected and analyzed, revealing a BAC of 0.21.
Allegedly, following her recovery, the defendant was charged with aggravated assault by vehicle while DUI and two DUI offenses. She moved to suppress the BAC evidence, arguing that her blood was drawn for legal, not medical, purposes and that its use in court violated her rights. The trial court admitted the BAC evidence under the medical records exception to the hearsay rule, leading to the defendant’s conviction. She subsequently appealed, raising several arguments concerning the admissibility of her medical records.
Grounds for Admission of Medical Records in DUI Cases
On appeal, the court examined whether the BAC results in the defendant’s medical records could be admitted as evidence. The court noted that under Pennsylvania law, medical records generated in the course of treatment are generally admissible as evidence under the business records exception to the hearsay rule.
Additionally, the court cited Pennsylvania case law establishing that medical records are not “testimonial” and, therefore, do not trigger confrontation rights under the Sixth Amendment. The court referenced a similar decision that established that medical BAC tests performed for treatment purposes are not subject to confrontation requirements because they are not created for law enforcement purposes.
Here, the court found that the hospital collected the defendant’s blood as part of routine trauma care following the accident. Therefore, it concluded that the BAC results were non-testimonial and admissible under the business records exception, regardless of any subsequent legal use.
The court rejected the defendant’s argument that Section 3755 of Pennsylvania’s Motor Vehicle Code, which permits emergency blood draws following DUI incidents, rendered her blood test testimonial. It noted that the record lacked evidence showing that the blood draw was conducted under Section 3755’s directive.
Instead, the hospital’s standard trauma protocol led to the collection and analysis of the defendant’s blood, and as such, the court upheld the admission of the BAC results as valid evidence.
Talk to a Dedicated Pennsylvania DUI Defense Attorney
If you were charged with a DUI offense involving medical evidence, it is essential to understand your options for challenging the evidence against you, and you should talk to an attorney. Attorney Zachary B. Cooper is an experienced Pennsylvania DUI defense lawyer who can evaluate the circumstances of your case and help you seek the best possible outcome. To schedule a confidential and free consultation, contact Mr. Cooper via the online form or call (215) 542-0800.