admission test in Hawaii

2025Spies’s remaining challenges are without merit and are addressed only to the extent necessary to resolve the pertinent issues here. 6 A. Foundation for Admission of Laboratory Test Results We begin with the single question the State presents in its cross-application for writ of certiorari: Whether the ICA gravely erred when it held that the State was required to lay a sufficient foundation showing an expert was trained to operate a balance, a UV spectrometer, and a FTIR spectrometer in accordance with the requirements and recommendations of the manufacturers of those instruments, prior to the

2025Spies’s remaining challenges are without merit and are addressed only to the extent necessary to resolve the pertinent issues here. 6 A. Foundation for Admission of Laboratory Test Results We begin with the single question the State presents in its cross-application for writ of certiorari: Whether the ICA gravely erred when it held that the State was required to lay a sufficient foundation showing an expert was trained to operate a balance, a UV spectrometer, and a FTIR spectrometer in accordance with the requirements and recommendations of the manufacturers of those instruments, prior to the

2025Spies’s remaining challenges are without merit and are addressed only to the extent necessary to resolve the pertinent issues here. 6 A. Foundation for Admission of Laboratory Test Results We begin with the single question the State presents in its cross-application for writ of certiorari: Whether the ICA gravely erred when it held that the State was required to lay a sufficient foundation showing an expert was trained to operate a balance, a UV spectrometer, and a FTIR spectrometer in accordance with the requirements and recommendations of the manufacturers of those instruments, prior to the

2025Spies’s remaining challenges are without merit and are addressed only to the extent necessary to resolve the pertinent issues here. 6 A. Foundation for Admission of Laboratory Test Results We begin with the single question the State presents in its cross-application for writ of certiorari: Whether the ICA gravely erred when it held that the State was required to lay a sufficient foundation showing an expert was trained to operate a balance, a UV spectrometer, and a FTIR spectrometer in accordance with the requirements and recommendations of the manufacturers of those instruments, prior to the

2025Spies’s remaining challenges are without merit and are addressed only to the extent necessary to resolve the pertinent issues here. 6 A. Foundation for Admission of Laboratory Test Results We begin with the single question the State presents in its cross-application for writ of certiorari: Whether the ICA gravely erred when it held that the State was required to lay a sufficient foundation showing an expert was trained to operate a balance, a UV spectrometer, and a FTIR spectrometer in accordance with the requirements and recommendations of the manufacturers of those instruments, prior to the

2025Spies’s remaining challenges are without merit and are addressed only to the extent necessary to resolve the pertinent issues here. 6 A. Foundation for Admission of Laboratory Test Results We begin with the single question the State presents in its cross-application for writ of certiorari: Whether the ICA gravely erred when it held that the State was required to lay a sufficient foundation showing an expert was trained to operate a balance, a UV spectrometer, and a FTIR spectrometer in accordance with the requirements and recommendations of the manufacturers of those instruments, prior to the

2025(Emphasis omitted.) 6 The other issues raised by Spies are: (1) whether exigent circumstances justified the warrantless seizure of Spies’s pickup truck; (2) whether the warrant for his person was supported by probable cause; (3) whether the charging instrument’s language was sufficient; (4) whether the warrant affidavit was sufficient to establish the reliability of the canine screen; and (5) whether the warrantless canine screen of Spies’s pickup truck violated Kyllo v. United States, 533 U.S. 27 (2001).

2025(Emphasis omitted.) 6 The other issues raised by Spies are: (1) whether exigent circumstances justified the warrantless seizure of Spies’s pickup truck; (2) whether the warrant for his person was supported by probable cause; (3) whether the charging instrument’s language was sufficient; (4) whether the warrant affidavit was sufficient to establish the reliability of the canine screen; and (5) whether the warrantless canine screen of Spies’s pickup truck violated Kyllo v. United States, 533 U.S. 27 (2001).

2016The expert in Manewa testified, “ ‘a routine check’ was done of the [instrument] ‘each and every morning’ ‘to ensure that all the parameters are within manufacturer specifications.’” Id. at 354 , 167 P.3d at 347 .

2016The expert in Manewa testified, “ ‘a routine check’ was done of the [instrument] ‘each and every morning’ ‘to ensure that all the parameters are within manufacturer specifications.’” Id. at 354 , 167 P.3d at 347 .

1987However, in Colorado, “Appendix A of the Department of Health rules and regulations provided a fourteen step operational checklist and procedure guide for intoxilyzer operators.” 4 Id. at 6 .

1987Likewise, in Aultman v. Motor Vehicle Division, Dept. of Revenue, 706 P.2d 5 (Colo. App. 1985), the court held that the introduction of the operational checklist for intoxilyzer operators and testimony that the checklist procedures were followed constituted sufficient foundation for the admission of the test result.

1987See People v. Adams, 59 Cal. App. 3d 559 , 131 *559 Cal. Rptr. 190 (1976); People v. Bowers, 716 P.2d 471 (Colo. 1986); 2 S. Gard, Jones on Evidence § 14.37 (6th ed. 1972).