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
- 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.
- 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.