Price v. State

Fletcher, Presiding Justice.

In a bench trial, Stacy Haygood Price was convicted of driving under the influence, driving with an unlawful alcohol concentration, and having no valid driver’s license. On appeal, Price contends that O.C.G.A. § 40-6-392 (e) violates her right of confrontation by permitting the use of a certificate to establish the qualifications of the blood drawer. Because the certificate is a public record and thus satisfies the reliability concerns of the confrontation clause, we uphold O.C.G.A. § 40-6-392 (e). However, we reverse Price’s conviction because the trial court…