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Keywords

appealtestimonywilldiscrimination
liabilityhearingtestimonymotionwilldiscrimination

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Hayes v. Commissioner of Public Safety, 773 N.W.2d 134

Facts

On April 13, 2008, Robert Laron Hayes was arrested by state trooper Kevin Kloss on suspicion of DWI after failing field sobriety tests. Following his arrest, Hayes provided a urine sample that revealed an alcohol concentration of .13. The commissioner of public safety subsequently revoked Hayes's driver's license. Hayes petitioned the district court to rescind the revocation, intending to introduce expert testimony to challenge the validity of the urine test, which he argued was flawed due to not voiding his bladder prior to providing the sample.

The commissioner of public safety revoked the driver's license of Robert Laron Hayes after he was arrested for driving while impaired (DWI) and submitted to a urine test, which revealed an alcohol concentration of .13. At the implied-consent hearing, the district court did not allow Hayes to introduce expert testimony concerning his urine test.

Issue

Did the district court err by excluding Hayes's proffered expert testimony concerning his urine test? Did the administration of Hayes's urine test violate his constitutional right to equal protection?

I. Did the district court err by excluding Hayes's proffered expert testimony concerning his urine test? II. Did the administration of Hayes's urine test violate his constitutional right to equal protection?

Rule

A district court may admit expert testimony if the expert's specialized knowledge will assist the factfinder to understand the evidence or to determine a fact in issue. The right to equal protection is violated only if there is intentional or purposeful discrimination.

A district court may admit expert testimony if the expert's specialized knowledge will assist the factfinder 'to understand the evidence or to determine a fact in issue.' Minn. R. Evid. 702. The right to equal protection is embodied in a provision that states: 'No member of this state shall be disenfranchised or deprived of any of the rights or privileges secured to any citizen thereof, unless by the law of the land.' Minn. Const. art. I, § 2.

Analysis

The court found that the district court did not abuse its discretion in excluding the expert testimony because it would not have been helpful to the factfinder in resolving the issues at hand. The court also determined that Hayes's equal protection argument failed because he did not demonstrate that the urine test was administered with intentional or purposeful discrimination, nor did he provide evidence of arbitrary decision-making by law enforcement.

In sum, the district court did not abuse its discretion by excluding the proffered expert evidence because the evidence would not have been helpful to the factfinder. Hayes does not argue that the collection of his urine sample was the result of 'intentional or purposeful discrimination,' nor did he offer any evidence to that effect.

Conclusion

The Court of Appeals affirmed the district court's decision, concluding that the exclusion of expert testimony was appropriate and that the urine test did not violate Hayes's equal protection rights.

The district court did not err by excluding Hayes's proffered expert testimony concerning the validity and reliability of his urine test. The district court did not err by ruling that the revocation of Hayes's driver's license was not a violation of Hayes's constitutional right to equal protection.

Who won?

The commissioner of public safety prevailed in the case because the court upheld the exclusion of expert testimony and affirmed the revocation of Hayes's driver's license.

The commissioner filed a pre-hearing motion in limine to exclude Burr's testimony on the ground that the urine-pooling theory has not been endorsed by the appellate courts.

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