Court of Criminal Appeals of Texas

Arturo Chavez Hernandez, Appellant v. the State of Texas

June 4, 20032003 Tex. Crim. App. LEXIS 102

Summary

The Court of Criminal Appeals of Texas affirmed the Corpus Christi Court of Appeals, holding that the trial court abused its discretion by admitting ADx analyzer urinalysis results because the State failed to satisfy the Kelly reliability requirements. It also held that a party need not always satisfy the Kelly test when the scientific principle is already generally accepted, and that subsequent parties need not repeat the first two prongs of Kelly once the principle has been validated.