State v. Bowen

Eldridge, Judge,

dissenting.

The majority parses OCGA § 52-7-12 (c) (1) and determines that although the APA does not apply to the first sentence, it applies to the second. I cannot agree.

OCGA § 52-7-12 (c) (1), regarding chemical testing to determine whether one is “boating” under the influence, mirrors OCGA § 40-6-392 (a) (1) (A) regarding the same chemical testing to determine whether one is “driving” under the influence. The language of both *163statutes was adopted, respectively, in 19921 and 1988.2 In 1997, however, the legislature “consolidated] and revise [d] the laws of this state relating to the Division of Forensic Sciences of the Georgia Bureau of Investigation and forensic testing of evidence.”3 In so doing, the legislature passed OCGA § 35-3-150 et seq. which outlined the duties of the GBI Forensic Division and permitted the division to adopt its own standards for chemical testing:

The Division of Forensic Sciences of the Georgia Bureau of Investigation: (1) Shall provide a state-wide system of laboratories dedicated to conducting forensic analysis of evidence submitted to the laboratory by law enforcement agencies, prosecuting attorneys, coroners, and medical examiners; (2) Shall provide forensic services to the criminal justice system for the examination and analysis of evidence [;] (3) Shall establish standards for the identification, collection, transportation, and analysis of forensic evidence; (4) Shall facilitate independent testing or analysis of evidence within the possession, custody, or control of the division as provided in paragraph (3) of subsection (a) of Code Section 17-16-4, relating to discovery in criminal cases.4

The legislature went further and permitted the Forensic Division to develop its own written guidelines for the administration of chemical testing:

The division shall: (1) Establish written standards and procedures for the administration of forensic testing. The division shall retain a copy of any procedure adopted pursuant to this paragraph which is modified for a period of five years from the date of its being superseded by the modification; (2) Adopt rules and regulations as required by law; and (3) In cooperation with the Georgia Peace Officer Standards and Training Council, provide for the training and certification of operators of such breath test equipment. A copy of such operator’s certificate shall be prima-facie evidence in any civil, criminal, or administrative proceeding that such oper*164ator was qualified to operate such equipment.5

After outlining the responsibilities of the Forensic Division and permitting the division to promulgate its own methods for the administration of tests, including certifying those who administer them, the legislature specifically exempted the methods promulgated by the Forensic Division from the APA:

Unless otherwise specifically provided by law, technical, scientific, and similar processes, procedures, guidelines, standards, and methods for the collection, preservation, or testing of evidence adopted by the division shall not be subject to the provisions of Chapter 13 of Title 50, the “Georgia Administrative Procedure Act.”6

Now, the majority holds that the legislature meant to exclude from the APA the methods the Forensic Division developed for the test, themselves, but to have the APA apply to the methods the division developed to certify the administrators of the tests. I cannot agree. Methods for administration are methods for administration. Administration is impossible without an administrator; the “methods developed for the administration” of chemical tests naturally include the administrators of those chemical tests. That is why the legislature permitted the division to certify its own test administrators and why a Forensic Division operator’s certificate is prima facie proof that the operator is qualified. I find that the majority’s distinction between test versus administrator has no rational basis under the statute, under the case law, under the legislative intent — which was to streamline the admissibility of chemical tests in criminal trials — or under plain old common sense.7 The officer in this case was certified by the Forensic Division for operation of the Intoxilyzer 5000. His certificate was tendered. The Forensic Division’s methods for certifying the officer are not applicable to the APA, regardless of whether the crime is prosecuted under OCGA § 52-7-12 or OCGA § 40-6-392. Granting Bowen’s motion to suppress was error as a matter of law. Accordingly, I dissent.

I am authorized to state that Presiding Judge Andrews and Judge Barnes join in this dissent.

*165Decided July 14, 2000 Jerry Rylee, Solicitor, Larry A. Baldwin II, Assistant Solicitor, for appellant. Chandler & Britt, Walter M. Britt, Deborah F. Weiss, for appellee.

Ga. L. 1992, p. 2079.

Ga. L. 1988, p. 1896.

(Emphasis supplied.) Ga. L. 1997, pp. 1421-1422. Thus, the majority’s review of the language of the older statute for “legislative intent” makes little sense. The legislature spoke quite clearly in adopting OCGA § 35-3-150 et seq. regarding the responsibilities of the GBI Forensic Division.

OCGA § 35-3-151.

(Emphasis supplied.) OCGA § 35-3-154.

(Emphasis supplied.) OCGA § 35-3-155.

See Love v. State, 271 Ga. 398, 399 (1) (517 SE2d 53) (1999) (“the Georgia General Assembly passed the Forensic Sciences Act, which made the APA inapplicable to the methods of evidence-testing adopted by the GBI’s Division of Forensic Sciences”); Price v. State, 269 Ga. 222, 225 (4) (498 SE2d 262) (1998); Hammontree v. State, 236 Ga. App. 342, 343-344 (2) (512 SE2d 57) (1999).