State v. Lozon

¶1 A jury convicted Stuart Laurence Lozon, Jr. (Lozon) of driving under the influence in the Twenty-First Judicial District Court. Lozon argues his conviction should be reversed because the District Court admitted the video of the Preliminary Alcohol Screening Test administration without sound over Lozon’s objection. We reverse.

¶2 We consider the following issue on appeal:

¶3 Did the District Court abuse its discretion by partially denying Lozon’s motion in limine to exclude video footage depicting administration of the PAST?

FACTUAL AND PROCEDURAL BACKGROUND

¶4 On July 6, 2010, Lozon was…