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.