State v. Helms
Supreme Court of North Carolina
1Opinion of the Court
FRYE, Justice.
Defendant appealed his conviction of driving while impaired in violation of N.C.G.S. § 20-138.1. He contended that the trial court erred by admitting into evidence the results of a horizontal gaze nystagmus (HGN) test without the establishment of a proper foundation. Defendant contended that the HGN test is a scientific test requiring expert testimony as to its reliability. The Court of Appeals agreed that the State failed to lay a proper foundation at trial for admission of the HGN test results. Nevertheless, the panel concluded that the error was harmless and upheld…
2Cases cited20 opinions
- Emerson v. StateCourt of Criminal Appeals of Texas · 1994
- State v. BullardSupreme Court of North Carolina · 1984
- State v. Superior CourtArizona Supreme Court · 1986
- People v. LeahyCalifornia Supreme Court · 1994
- State v. GoodeSupreme Court of North Carolina · 1995
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3Cited by24 opinions
- State v. BaueNebraska Supreme Court · 2000
- People v. McKownIllinois Supreme Court · 2007
- United States v. HornDistrict Court, D. Maryland · 2002
- State v. DoriguzziNew Jersey Superior Court Appellate Division · 2000
- State v. HelmsSupreme Court of North Carolina · 1998
19 more not listed; retrieve them via the Exa API.