Court of Criminal Appeals of Texas
Jerry Glenn Reynolds, Ii, Appellant v. the State of Texas
October 18, 20062006 Tex. Crim. App. LEXIS 2038
Summary
The Texas Court of Criminal Appeals affirmed the Amarillo Court of Appeals, holding that certification and supervisory oversight, not the operator’s personal scientific knowledge, satisfy the admissibility requirements for breath‑test evidence. The Court also concluded that Slagle did not overrule Hill and that the Kelly criteria are met by certification alone. Accordingly, the trial court’s pre‑trial ruling admitting the breath‑test results stands.