Stevens v. State

Supreme Court of the State of Delaware · 2025 · Evidence

Evidenceexpert testimonyscientific evidencefoundationtoxicologyD.R.E. 702D.R.E. 703scientific instrument

Facts

After Stevens was arrested on suspicion of driving under the influence of drugs, police obtained a blood sample that was tested at the Delaware Division of Forensic Services. Preliminary ELISA testing indicated the presence of a benzodiazepine and fentanyl, and LC-MS/MS testing confirmed the presence of flubromazepam and fentanyl. At trial, three forensic experts testified that the LC-MS/MS machines were properly calibrated or maintained and that they relied on actual calibration data or similar testing, but the underlying calibration documents were not introduced into evidence. Stevens repeatedly objected that the State had failed to lay a sufficient foundation because it had not introduced records showing the machines were calibrated and in working order.

Issue

Must the State, as a foundational prerequisite to admitting LC-MS/MS blood-test toxicology results, introduce calibration records or certifications showing that the machines were operating accurately? More specifically, does McConnell impose a bright-line rule requiring such documentation for laboratory blood-test evidence?

Rule

When evidence is obtained from a scientific instrument, expert testimony is necessary to establish the instrument's reliability and accuracy. For LC-MS/MS laboratory blood testing, qualified experts may testify to reliability based on facts or data, including calibration data, that experts in the field reasonably rely on, and D.R.E. 703 does not require those underlying data themselves to be admitted. McConnell does not create a bright-line rule requiring calibration documents to be introduced before LC-MS/MS results are admissible.

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In a prosecution in Dover for driving under the influence of drugs, the State offers blood-test results generated by an LC-MS/MS machine at Pine Harbor Forensic Laboratory. A forensic chemist testifies that she reviewed the machine-specific calibration run performed that morning and, based on that data, concluded the instrument was operating properly, but the State does not move the calibration printout into evidence.

Should the trial court admit the LC-MS/MS results over the defendant's foundation objection that the calibration printout itself is missing from evidence?

Explanation. When evidence comes from a scientific instrument, expert testimony is needed to establish reliability and accuracy. But the majority held that for LC-MS/MS blood testing, qualified forensic experts may base their opinions on calibration data under D.R.E. 703 without requiring the calibration documents themselves to be admitted. There is no bright-line rule demanding introduction of calibration records as a foundational prerequisite. (Derived from Stevens v. State (n.d.).)