## Facts

- Julian R. (“Randy”) Suttle was involved in a late-night truck collision that killed Howard Deavers, a passenger in the other vehicle.
- Suttle was taken to Selma Medical Center shortly after midnight for treatment.
- After 1:00 a.m., a nurse drew two vacuum-type blood vials from Suttle, labeled them with his name, and gave them to a state trooper at the hospital.
- The nurse testified the vials were not taped when transferred to the trooper.
- The trooper died before trial and did not testify about the vials’ handling, storage, or mailing after receipt.
- Four days later, a forensic toxicologist retrieved a sealed mailing cylinder from a department post office box containing two blood vials labeled with Suttle’s name and the date of the draw.
- The toxicologist could not identify who mailed the package, when it was mailed, or where the vials were kept before receipt; the vials appeared taped when received.
- Over objection, the trial court admitted the vials and toxicology testimony that one vial tested at 0.29% blood-alcohol concentration.
- Suttle was convicted of vehicular homicide and sentenced to five years’ imprisonment.

## Issues

1. Whether the State established a sufficient chain of custody for fungible blood evidence when no evidence accounted for the sample’s handling during a four-day interval between hospital transfer to an officer and receipt by the toxicologist.
2. Whether the admission of the blood vials and blood-alcohol testimony was erroneous and required reversal where a key custodian did not testify and the condition of the vials differed at collection and receipt.

## Decision

- The Alabama Court of Criminal Appeals reversed the conviction and remanded.
- The court held the State failed to establish a proper chain of custody for the blood sample.
- The four-day, unexplained gap in custody constituted a “missing link,” making the blood evidence inadmissible.
- The discrepancy between the nurse’s testimony (untaped vials) and the toxicologist’s receipt (taped/sealed packaging) reinforced the failure to show no reasonable probability of tampering.
- Because the blood-alcohol evidence was highly prejudicial and central to the prosecution’s case, its admission required reversal.

## Legal Principles

- The purpose of a chain of custody is to show, to a reasonable probability, that evidence has not been tampered with.
- For fungible evidence (including blood drawn for chemical analysis), the State must identify and account for each link in the chain, including receipt, safeguarding, and disposition.
- A “weak link” generally affects weight; a “missing link” (an unaccounted-for custodian or unexplained interval) renders the evidence inadmissible.
- Where the State cannot show who possessed the evidence, how it was stored, or how it was transferred during a material interval, admission of the evidence is error.

## Conclusion

The court reversed and remanded because the State could not account for the blood sample’s custody for four days after it left the nurse’s control, creating a missing link that rendered the blood-alcohol evidence inadmissible and prejudicial to the verdict.


Suttle v. State, 565 So. 2d 1197 (Ala. Crim. App. 1990)