Stash v. Commissioner of Motor Vehicles, 297 Conn. 204

Summary

The Supreme Court of Connecticut affirmed judgments upholding ninety-day driver's license suspensions imposed after Adam Stash and James R. Marsh III failed Intoxilyzer breath tests. The court rejected their arguments that the breath-test results were insufficient to establish the statutorily defined elevated blood alcohol content because no mathematical conversion or margin-of-error evidence had been presented. The court adopted the trial court's reasoning and concluded that substantial evidence supported the administrative findings.

Holdings

1. The agency had substantial evidence to conclude that the plaintiffs had operated their vehicles with an elevated blood alcohol content; separate proof of a mathematical conversion from the Intoxilyzer's breath measurement to a blood alcohol ratio was not required on this record.
2. The plaintiffs did not establish that their own Intoxilyzer readings were inaccurate or fell within any asserted margin of error, and the hearing officer was not required to credit the contrary expert testimony.
3. Marsh's appeal was not moot because the potential collateral consequences of a license suspension, including enhanced penalties for successive violations, could provide practical relief.

Questions Presented

1. Whether Intoxilyzer breath-test results expressed as a weight-of-alcohol-to-volume-of-breath ratio sufficiently established the elevated blood alcohol content defined by General Statutes § 14-227b(o), without separate proof of a mathematical conversion to a weight-of-alcohol-to-weight-of-blood ratio.
2. Whether evidence concerning a possible margin of error or general inaccuracy of Intoxilyzer results required rejection of the agency's findings when the plaintiffs did not establish that their own test results were inaccurate or within the asserted margin of error.
3. Whether Marsh's appeal was moot because his license suspension likely had expired.

Disposition

affirmed