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Dromgoole, Melissa
Citation: Not availableDocket: PD-1230-15
Court: Court of Appeals of Texas; October 20, 2015; Texas; State Appellate Court
Original Court Document: View Document
The document pertains to the case of Melissa Dromgoole (Appellant) vs. The State of Texas (Appellee), identified as PD-1230-15 in the Court of Criminal Appeals of Texas. It includes a petition for discretionary review from the Court of Appeals for the First Judicial District of Texas. The parties and their counsel are listed, including Appellant Melissa Dromgoole and various attorneys from both sides involved in the trial and appeal processes. The content outlines critical questions for review, specifically addressing the obligations of police officers concerning a suspect’s claimed medical incapacitation during a blood draw, the standard used by the court of appeals regarding the reasonableness of nonconsensual blood tests, and the reliability of blood analysis techniques used by the HPD Crime Lab. Key arguments include: 1. **Police Duty**: Whether officers should investigate a suspect's medical condition further or inform medical personnel before proceeding with a blood draw. 2. **Standard of Review**: The court of appeals employed a rigid rule instead of a totality of circumstances approach regarding the reasonableness of the blood draw, imposing an unreasonable burden on the suspect. 3. **Reliability of Blood Testing**: The court’s analysis of blood testing techniques did not adequately consider established reliability factors (Kelly factors) and failed to recognize substantial procedural errors at the lab. The document concludes with sections for a prayer, certificates of service and compliance, and an appendix. The document presents an index of authorities, including relevant cases, statutes, and constitutional provisions, which are cited in the context of a legal appeal involving Melissa Dromgoole. Dromgoole was charged with a Class A misdemeanor for driving while intoxicated, found guilty by a jury, and sentenced to one year of probation and a $500 fine. She subsequently filed a timely notice of appeal, which the trial court certified. The procedural history details that the First Court of Appeals affirmed her conviction on June 4, 2015, but later issued a modified opinion following a motion for rehearing. The court denied further rehearing requests. Dromgoole's petition for discretionary review raises key questions: 1. Whether police officers must investigate a suspect's claimed medical condition before carrying out a blood draw. 2. Whether the court of appeals erred by applying a per se rule instead of a totality of the circumstances approach regarding the reasonableness of a nonconsensual blood test. 3. Whether the appellate court failed to consider the Kelly factors when assessing the reliability of the blood testing technique used by the Houston Police Department Crime Lab, which did not adhere to basic industry standards. Dromgoole anticipates that oral arguments will assist the court in addressing the novel issues presented, particularly concerning Fourth Amendment rights. Review of the unreasonable blood draw is warranted as the court of appeals established a rigid standard for medical exemptions that conflicts with established case law (State v. Johnston, 336 S.W.3d 649, 658-59). During a traffic stop, the Appellant informed the arresting officer of her medical condition, syncope, which can cause fainting due to low blood pressure. Despite her explanations, Officer Nunn considered her condition an excuse for non-compliance. After a warrant was obtained, a blood draw was conducted without prior assessment of the Appellant’s medical history or vital signs, despite the nurse being trained to adjust procedures for patients with fainting issues. Expert testimony from Appellant’s physician indicated that standard sitting positions for blood draws could be dangerous for patients with syncope, recommending that such patients should lie flat and have their blood pressure monitored. The court of appeals ruled the blood draw unconstitutional under the Fourth Amendment, stating the Appellant failed to adequately inform police of the risks associated with her condition. This decision imposes an unreasonable burden on DWI suspects that exceeds the requirements set forth in Johnston, which does not mandate prior medical history inquiries as a blanket rule against the reasonableness of blood draws. The Court established that DWI suspects must demonstrate how a venipuncture blood draw is unreasonable for them individually, as indicated in Schmerber. Suspects are best positioned to reveal any medical conditions that could pose risks or cause significant pain during the procedure. Reasonableness is assumed unless evidence shows a specific medical condition that renders the blood draw unreasonable. A suspect's responsibility includes identifying and disclosing such conditions and providing evidence to support their claims. Additionally, the Court mandated that police officers must appropriately address any medical disclosures made by suspects. The "deliberate and conscientious" standard requires officers to investigate unfamiliar disclosed medical conditions before executing a blood draw warrant. For instance, if a suspect reports a condition like low blood pressure, officers should inquire about its potential impact on the blood draw's safety or inform medical personnel of the condition. The appellate court's imposition of a burden on suspects to assert medical exemptions post-arrest is deemed unreasonable, as current procedures do not facilitate this assertion. The court criticized the appellant for disclosing her condition outside the context of a blood draw. However, it is inappropriate to expect a suspect to provide this information during a consent request or warrant situation. Under Texas law, a DWI arrestee has an absolute right to refuse a specimen, and such a refusal should not require justification. The existing consent request procedures do not allow for a logical opportunity to assert a medical exemption, as suspects face legal forms detailing the consequences of refusal without any indication of the need to disclose relevant medical conditions. Written warnings provide suspects with the right to a hearing regarding a license suspension but do not mention the right to a medical exemption. The form allows suspects to refuse consent without providing space for justifying reasons, and there is no indication that suspects are expected to volunteer such information. Officer Nunn disregarded reported medical conditions as “excuses” and characterized the Appellant as uncooperative. The only chance for a suspect to claim a medical exemption arises when presented with a warrant, which does not allow them to resist the search. Police can use force to obtain a blood sample from uncooperative DWI suspects under a warrant. An incapacitated arrestee may not be able to articulate objections, raising concerns about their ability to assert constitutional rights. The Supreme Court has stated that defendants should not be penalized for failing to request counsel when they do not understand their rights, a situation that is exacerbated for impaired or ill suspects. In evaluating Fourth Amendment reasonableness, courts consider the totality of circumstances rather than applying per se rules. The court of appeals' rigid approach fails to account for the context of a suspect’s disclosures that may alert an officer to potential risks, even if specifics are not provided. In this case, the Appellant communicated a medical condition related to low blood pressure and fainting, which should have prompted further investigation by Officer Nunn before proceeding with a nonconsensual blood draw. Nunn's inaction rendered the blood draw unreasonable. Review is necessary to clarify the burden on suspects asserting a medical exemption for blood draws, as well as to address the court of appeals' misapplication of legal standards as outlined in Kelly v. State. When analyzing Appellant's blood specimen, the HPD Crime Lab deviated from industry standards by not conducting the test using a validated method. State experts indicated that lab protocols and accrediting agency standards mandate adherence to validated methods for all casework. A validation study, conducted after significant replacements in the headspace chromatograph, aimed to ensure reliable results at specific settings. The validation report noted a vial oven temperature of 70 degrees Celsius, but documentation revealed that the fundamental components were run at 60 degrees, with the adjustment to 70 degrees made only on the study's final day and not applicable to core components. Although criminalist L. Mayor and supervisor W. Arnold asserted the reliability of the test results, their reasoning was inadequate. They claimed temperature changes would not affect the results due to the ratio measurement between a known standard and unknown sample content, relying on the assumption of proper machine function. Furthermore, while they cited the routine testing of controls to ensure accuracy, they acknowledged that control use does not replace the necessity for method validation, which is essential before interpreting any results. Appellant contended the State did not provide clear and convincing evidence of the blood test's reliability, as required by the Kelly analysis, with no established validity within the scientific community. The Court of Appeals, however, refrained from applying the Kelly criteria, framing the issue as one of credibility and deferring to the trial court's discretion in favor of the State. This approach conflicted with the Kelly decision, which delineates three necessary criteria for scientific evidence: the validity of the underlying scientific theory, the validity of the technique employed, and the proper application of that technique in the specific instance. Seven non-exclusive factors were identified for assessing the reliability of scientific techniques in court: (1) acceptance of the scientific theory by the relevant community, (2) qualifications of the expert witnesses, (3) literature supporting or opposing the scientific theory, (4) potential error rate of the technique, (5) availability of other experts for evaluation, (6) clarity of explanation to the court, and (7) experience of those applying the technique. The court of appeals ruled that these factors were not applicable, viewing the appellant's challenge as an improper application rather than a validity issue, characterizing the lab's error as an "inadvertent variance." However, it was noted that this was not a single instance but a sustained practice that lacked proper validation after equipment changes. Testimonies indicated that lab personnel believed their temperature adjustments were authorized and appropriate. The lab's failure to conduct a full validation study undermined the reliability of all subsequent forensic results obtained under unvalidated conditions. Judicial notice regarding the reliability of the unconventional technique was deemed inappropriate since no court had evaluated the specific practice in question. The court acknowledged that gas chromatography can be reliable only when using validated instruments, which was not the case here. The absence of a full validation study and reliance on controls instead indicated a significant deviation from industry standards, necessitating a thorough reliability assessment under the Kelly factors. The court of appeals failed to apply the rigorous Kelly factors necessary for evaluating expert testimony in hard sciences, mistakenly treating the analysis as appropriate for "soft" sciences. The Kelly factors require the court to assess the legitimacy of the field, the relevance of the expert's subject matter, and the proper application of field principles. In this case, forensic chemistry is classified as a hard science, demanding a stringent analysis. The court of appeals focused narrowly on Henry’s Law, which indicates that temperature changes should not affect the ratio of volatile compounds in a closed environment, but overlooked the critical issue of whether changes in the instrument's settings compromised its functionality. The testimony provided by an expert, Arnold, suggested that a 10-degree temperature change would not impact results; however, he could not confirm that such a change had no unexpected consequences on the machine. The appeals court erred by accepting Arnold's explanation without requiring the State to provide evidence demonstrating that the lab's deviation from validated parameters was scientifically accepted, supported by literature, had a known error rate, and was evaluated by other experts. The court reduced the analysis to a credibility determination instead of adhering to the required burden of proof, which mandates that the proponent of expert testimony must demonstrate its reliability by clear and convincing evidence. Consequently, even if Arnold's assertions were credible, the State did not sufficiently establish the reliability of its unconventional techniques. State experts failed to provide evidence that the lab's deviation from validated parameters was accepted by the scientific community or supported by literature. Their testimony consisted of mere assurances regarding the lab's reliance on controls instead of proper validation for machine accuracy. The court of appeals improperly required the Appellant to disprove the State's evidence concerning Henry’s Law, a shift in burden inconsistent with the Kelly standard. The State did not produce credible evidence to support its unconventional methods as scientifically reliable. The appellate review of expert testimony necessitates rigorous examination to ensure adherence to accepted scientific methods, which was lacking in the court of appeals' analysis. The Appellant seeks discretionary review to reverse the conviction and remand for a new trial. The document also includes a certificate of service, confirming electronic notification of involved parties, and a compliance certificate detailing the document's word count. The case involves an appeal by Melissa Dromgoole, convicted for driving while intoxicated, who contends that the trial court erred in denying her motion to suppress and admitting the blood-test evidence. The appellate court issued a new opinion and judgment, affirming the modified judgment. Officer D. Nunn of the Houston Police Department initiated a traffic stop after being nearly struck by Appellant, who was subsequently pursued for running two red lights. Upon stopping her, Nunn observed signs of intoxication, including glassy eyes, slurred speech, and the smell of alcohol; Appellant admitted to consuming two drinks. Nunn conducted field sobriety tests, during which Appellant displayed indications of intoxication. Appellant reported having syncope, a condition characterized by fainting spells, which she described as low blood pressure. Despite this, Nunn arrested her and transported her to the police station, where Appellant claimed difficulties exiting the vehicle due to her condition but was later able to do so without showing any symptoms of dizziness or lightheadedness. At the station, Appellant engaged in a fistfight with another detainee, after which Nunn sought a warrant for a blood draw when she refused to provide a sample. The blood draw, conducted under the warrant, revealed a blood alcohol concentration of 0.17 grams per 100 milliliters. Appellant filed a motion to suppress the blood test results, arguing that the warrant affidavit failed to acknowledge her syncope and that her medical condition rendered the blood draw unreasonable under the Fourth Amendment. During the suppression hearing, Dr. J. Varon testified regarding Appellant’s syncope diagnosis, clarifying that she does not have low blood pressure and that her symptoms do not impact her blood pressure status. Dr. Varon testified that Appellant may have been experiencing pre-syncope during her field sobriety tests, which could have affected her performance. He indicated that for the walk-and-turn test, it was “more likely than not” that her difficulties were linked to pre-syncope, while for the other two tests, he stated it was merely possible. He noted the risks of performing a blood draw on someone experiencing syncope, recounting an incident where Appellant fainted during one draw and experienced a pre-syncope episode during another, which he managed by having her lie down. The trial court denied a motion to suppress evidence related to the blood test. Appellant objected to the blood test's admissibility, arguing that the testing machine had not been properly validated, citing a temperature discrepancy during the validation process where the oven was set at 60 degrees Celsius instead of the required 70 degrees on three out of four days. State witnesses, including Mayor and W. Arnold, testified that the temperature variation did not impact the machine’s validation, as the test relied on the ratio of alcohol to a control compound, which would remain accurate despite the temperature change. They also confirmed that known concentration samples were tested with every suspect's blood, ensuring any deficiencies would be detected. Appellant's subpoenaed witness, Irma Rios, supported the State's position, asserting the temperature difference would not affect the validation's reliability. Appellant’s expert, A. Culbertson, argued that proper validation of the machine was essential for reliable results, contending that routine control measurements could not confirm proper validation. The trial court denied Appellant's second motion to suppress blood-draw evidence, finding the testimonies of Mayor and Arnold credible and the blood test results reliable. Appellant contended that the court abused its discretion by denying the motion, arguing that her medical condition was not included in the warrant affidavit and that the blood draw was unreasonable given her condition. In reviewing the suppression hearing, the standard of review favors the trial court's ruling, granting it deference on factual determinations, especially regarding witness credibility. The trial court is the exclusive fact-finder, and its decisions will not be overturned unless unsupported by the record. The burden of proof for the motion to suppress rests on the defendant, who must rebut the presumption of proper police conduct, particularly since it was agreed that the blood was drawn following a warrant. Appellant claimed the draw violated her Fourth Amendment rights against unreasonable search and seizure, citing Schmerber v. California, which establishes a two-part analysis for assessing the legality of blood draws: 1) whether police were justified in requiring the test and 2) whether the means and procedures used adhered to Fourth Amendment standards of reasonableness. The analysis of "means and procedures" involves evaluating both the reasonableness of the test itself and the manner in which the test was performed. If Appellant challenges the blood draw due to an unreasonable medical risk stemming from her condition, she must additionally demonstrate specific elements supporting her claim. Extraction of blood samples for alcohol testing is generally considered a safe and effective method, with venipuncture blood draws deemed presumptively reasonable under the Fourth Amendment for most individuals. To contest this presumption, a defendant must demonstrate that they belong to a limited group who may have valid concerns—such as fear, health issues, or religious beliefs—against such testing methods. Specifically, the defendant carries the burden to inform the officer or the blood draw technician of any relevant medical conditions that could render the procedure unreasonably risky. Claims of fear must be substantiated; mere expressions of reluctance or general concerns are insufficient to establish the fear exception. The law requires that the reasonableness of a blood draw is assessed based on the facts known to the officer at the time of the procedure, not on information presented later during a motion to suppress. Consequently, a defendant cannot rely on new evidence introduced at a suppression hearing to argue against the reasonableness of the blood draw; they must prove that the procedure was not a reasonable means of assessing their blood alcohol level. A defendant asserting that a blood draw presents an unreasonable medical risk must demonstrate, at a motion to suppress hearing, the existence of a medical condition that creates such a risk and that the authorities were adequately informed about this condition. To successfully suppress a blood draw as an unreasonable search and seizure, the defendant must prove one of the following: (1) the police lacked justification for requiring the blood test, (2) the method of drawing blood was unreasonable, or (3) the blood draw procedure was unreasonable. If the defendant aims to prove the second or third points through a medical condition, she must additionally establish: (1) she has a medical condition, (2) it poses an unreasonable risk during a blood test, and (3) she properly notified law enforcement or the blood draw personnel of this risk. In the context of a warrantless blood draw, as analyzed in Schmerber, the presence of a valid warrant typically justifies the seizure. However, the defendant challenges the validity of the warrant by claiming the supporting affidavit omitted her medical condition (syncope) and that symptoms of pre-syncope could explain her failure on a field sobriety test. Under the Fourth Amendment, if an affidavit contains intentional or reckless misrepresentations or material omissions that affect probable cause, the warrant can be rendered invalid. The defendant bears the burden of proof at a Franks hearing to show these inaccuracies. If successful, the court reassesses probable cause without the false information, and if probable cause is lacking, the warrant is voided, necessitating the suppression of any evidence obtained from the search. The appellant specifically argues that the affidavit's failure to mention her syncope invalidates the warrant. Appellant argues that the magistrate could have determined that performing a blood draw on her, given her condition of syncope, presented an unreasonable risk of trauma or excessive pain. However, this argument is considered redundant in the context of the Schmerber analysis, which requires an evaluation of whether the method or performance of a blood draw was unreasonable. If deemed unreasonable, the evidence obtained must be suppressed, regardless of the magistrate's potential decision on the motion. Appellant’s second assertion regarding the warrant's validity is that the symptoms of pre-syncope may explain her failure on the field sobriety tests. Officer Nunn conducted three tests where Appellant showed signs of intoxication. Dr. Varon, testifying at the suppression hearing, suggested that pre-syncope could have influenced her performance, particularly stating it was “more likely than not” related to her difficulties with the walk-and-turn test. Even if Officer Nunn omitted Appellant's syncope diagnosis from his probable cause affidavit, its inclusion would not negate the probable cause for the warrant. Probable cause is assessed based on the totality of the circumstances, wherein the presence of alcohol consumption, erratic driving, and poor performance on sobriety tests all contributed to a fair probability that evidence of intoxication would be found. The possibility of an innocent explanation for failing the tests does not undermine the probable cause, as the overall circumstances supported a reasonable suspicion of legal intoxication. Appellant's claim that the blood draw constituted an unreasonable seizure due to her medical condition of syncope is overruled. In her affidavit, she expressed a prior experience of blacking out during blood tests. However, the trial court is afforded deference in determining the credibility of witness testimony. During a field sobriety test, Officer Nunn inquired about Appellant's medical conditions, to which she disclosed her syncope, describing it as low blood pressure. Contrarily, Dr. Vargas testified that Appellant’s blood pressure is normal and her syncope does not affect it. Even if Officer Nunn had a duty to inform the blood draw personnel of health issues, a warning about low blood pressure would not suffice to prevent an unreasonable blood draw. The court emphasized that blood draws are generally considered reasonable unless a defendant demonstrates a specific risk due to medical conditions or other valid reasons. The responsibility lies with the defendant to sufficiently inform the officer of any potential medical risks associated with the blood draw. Merely stating the name of a medical condition without clarifying its implications does not satisfy this burden. Appellant also referenced her difficulty exiting the police vehicle as an indication of the risk, but her vague assertions about notifying the officer did not provide enough detail to demonstrate that she adequately communicated the potential danger associated with the blood draw. Officer Nunn's testimony revealed that Appellant initially claimed she could not exit the vehicle due to low blood pressure but managed to get out ten minutes later. Although Appellant mentioned that her condition could lead to dizziness or faintness, she did not demonstrate how this constituted adequate notice that a blood draw would pose an unreasonable medical risk. Dr. Varon testified that Appellant’s symptoms were related to syncope, which carries some risk during a blood draw. However, there was no evidence that Officer Nunn could reasonably connect Appellant's reported symptoms to such a risk, especially since she engaged in a fistfight with another detainee without showing any symptoms. Even if Officer Nunn had a duty to report Appellant's medical conditions to the person performing the blood draw, there was no evidence indicating that terms like syncope or the assertion of occasional fainting should have raised concerns about increased medical risks. Consequently, Appellant did not meet her burden of proving that her disclosures warranted a conclusion that the blood draw would create an unreasonable risk of medical harm. Regarding Appellant's argument that the trial court erred in denying her motion to suppress blood-draw evidence due to statutory prohibitions, the court emphasized that statutory interpretation is a legal question reviewed de novo. The court aims to discern the Legislature's intent through the plain language of the statute, considering it as a whole rather than in isolation. The State contends that Appellant has waived her appeal issue because it differs from her trial complaint, citing TEX. R. APP. P. 33.1(a)(1)(A) and the case Curiel v. State, which requires consistency between trial objections and appellate arguments. Appellant's trial argument focused on the Texas Transportation Code Chapter 724, asserting that the legislature did not intend for first-time DWI offenders without aggravating circumstances to be subject to nonconsensual blood draws. On appeal, she claims Chapter 724 prohibits such actions absent specific aggravating circumstances outlined in section 724.012(b). The State argues that Appellant's reliance on section 724.013 in her appeal, which she did not cite at trial, constitutes a different argument. However, the court finds that Appellant preserved her argument since presenting the basis for her complaint suffices for preservation, and adding statutory details does not alter the original argument. The analysis reveals that section 724.012 outlines when law enforcement may require blood or breath tests, while section 724.013 states that if a suspect refuses such tests, a specimen cannot be taken unless specified circumstances exist. Appellant argues that, under Chapter 724, her refusal to submit to a blood test prohibits its extraction regardless of a warrant. The State counters with the precedent from Beeman v. State, noting that Chapter 724 relates to implied consent and, if a valid search warrant is obtained, the need for consent is moot, making Chapter 724 independent of Fourth Amendment search warrant law. Appellant counters that Beeman's analysis is undermined by later U.S. Supreme Court rulings in Missouri v. McNeely and Aviles v. Texas. The Court of Criminal Appeals has reaffirmed the relevant aspects of the Beeman decision, indicating that an officer can obtain a search warrant for a blood draw even when implied consent statutes could allow for involuntary blood draws, as established in Villarreal. The court clarified that this authority exists “even where” Chapter 724 permits mandatory blood draws. The validity of Beeman remains intact despite potential uncertainties following McNeely. The appellant contested the admission of blood test results, arguing they were unreliable under Rule 702 of the Texas Rules of Evidence. The standard for reviewing such admissions is whether the trial court acted arbitrarily or unreasonably, and the ruling is upheld if it falls within a reasonable range of disagreement. Rule 702 allows expert testimony if it aids in understanding evidence, provided the scientific theory, technique, and its application are valid. The appellant's reliance on the factors from Kelly for assessing reliability is misplaced, as the Reynolds case dictates a modified approach for breath test reliability assessments. The Texas Legislature has established the validity of the underlying science for breath tests, permitting their use if conducted by individuals certified and following methods approved by the Texas Department of Public Safety (DPS). In a Kelly hearing related to breath tests, the trial court's sole focus is on whether the technique was properly applied according to DPS rules for the specific instance in question. The Court of Criminal Appeals referenced Section 724.064 of the Texas Transportation Code, which allows alcohol concentration evidence from blood, breath, or urine analysis to be admissible in criminal proceedings under Chapter 49 of the Penal Code, affirming the validity of both blood and breath tests. The court noted that scientific reliability for breath tests is established as long as DPS requirements are met; however, there is no equivalent statute for blood tests that confirms the reliability of the techniques used. Consequently, the State bears the burden of demonstrating the reliability of blood test techniques. In a modified Kelly hearing concerning blood-alcohol tests, the trial court must assess both the validity of the technique applying the scientific theory and its proper application at the time of testing. The court clarified that a full Kelly analysis is not necessary to evaluate the reliability of the specific blood test method known as headspace gas chromatography. A court may take judicial notice of the reliability of a specific type of scientific evidence once it is well established, relieving the proponent from the burden of proof regarding its reliability. This principle applies after a Daubert/Kelly hearing has confirmed the scientific validity of a methodology, allowing other courts to accept the conclusions reached about that methodology's reliability or unreliability. Headspace gas chromatography is recognized as a reliable method for testing blood alcohol concentration and is generally accepted in the scientific community. Texas and federal courts have upheld this method's validity, negating the need for repeated Kelly analysis in subsequent cases where its reliability has been established. In the current appeal, the appellant does not contest the first two elements of the Kelly test but argues that a variation in the blood testing technique undermines its reliability. The State, however, asserts that this variation was inadvertent and does not represent a new method, maintaining that the existing technique was applied correctly. The court agrees with the State, noting that any challenge to a minor, inadvertent variance in technique should focus on the proper application of the established method, rather than the introduction of a new technique. The assessment of whether the technique was properly applied is case-specific. In challenges to scientific evidence reliability, the State must demonstrate that reliability by clear and convincing evidence during the hearing. In Schultz v. State, the court addressed the validity of a blood test following a challenge regarding the proper functioning and validation of the testing machine. The appellant contended that the blood draw technique was improperly executed because the testing machine had not been adequately validated after component replacements. Validation involves setting specific parameters and testing known alcohol concentration samples to ensure the machine's accuracy in reporting results. Key issues included that the vial oven of the machine, which should be set at 70 degrees Celsius (158 degrees Fahrenheit) for validation, was instead set at 60 degrees Celsius (140 degrees Fahrenheit) for three of the four days of the validation process. The appellant argued this discrepancy indicated the machine was not properly validated, thereby undermining the reliability of the blood test results. The court noted that, while there was evidence suggesting the incorrect setting of the vial oven, it could affirm the trial court's ruling without resolving this dispute. The machine tests alcohol concentration by measuring the volume of alcohol released into the air from a blood sample mixed with a chemical (n-Propanol), and the temperature of the vial oven is critical for accurate results. The appellant asserted that the State did not meet its burden to demonstrate the proper application of the blood draw technique due to the validation issues. Heating a liquid solution leads to the volatilization of compounds like alcohol, which then accumulates in the headspace of a sealed vial. Testing of this headspace measures the presence of alcohol, n-Propanol, and other chemicals. According to Henry’s Law, in a closed system at a constant temperature, the volume of these volatile compounds in a liquid is proportional to their concentration in the headspace. When applied to blood tests, this means that a specific blood alcohol concentration will yield a predictable amount of alcohol in the headspace when heated. For instance, blood with double the concentration of alcohol will release double the amount into the headspace. During blood testing, results are derived from the ratio of alcohol to n-Propanol in the headspace, rather than just the total amount of alcohol. A consistent amount of n-Propanol is added to each sample, ensuring that any increase in temperature impacts both alcohol and n-Propanol equally, thus maintaining their ratio. Arnold, a key witness, clarified that while temperature changes affect the total quantities of volatiles, they do not alter the alcohol-to-n-Propanol ratio, ensuring accurate results. Additionally, Arnold and other experts testified that the validation of the testing process remained reliable despite temperature variations, as samples with known concentrations continued to yield expected measurements. The validation aims to confirm that the machine's results fall within acceptable ranges for samples of known concentrations. Arnold, Mayor, and Rios testified that testing of blood samples includes known concentration samples to validate machine performance, asserting that consistent reporting of expected measurements indicates no impact from changes in oven temperature. Appellant's expert, Culbertson, disagreed, stating that proper validation is essential for reliable results, and merely measuring controls during testing does not confirm validation. She did not challenge Arnold's assertion that the alcohol to n-Propanol ratio remains constant despite temperature changes. The Appellant argued that if the evidence is considered reliable, then industry standards for validation and documentation become irrelevant, which the court rejected. The trial court is afforded significant discretion in assessing evidence credibility and determining whether the State sufficiently proved the technique's proper application. The court found the testimonies of Mayor and Arnold credible and ruled that the State met its burden of establishing reliability, indicating no abuse of discretion in admitting the evidence. Additionally, the trial court’s judgment noted that the State's enhancement paragraph was marked "n/a," meaning "not applicable." An appellate court can correct errors in judgments regardless of party requests or trial court objections, as established in French v. State and further supported by Rhoten v. State. The Texas Rules of Appellate Procedure explicitly allow modification of trial court judgments. In this case, the State’s amended information included an enhancement paragraph, which the trial court validated during the punishment phase. This finding was necessary to ensure the appellant's sentence fell within the lawful punishment range for misdemeanors. Consequently, the judgment will be modified to reflect the trial court's acknowledgment of the enhancement, and the modified judgment is affirmed. The panel includes Justices Jennings, Higley, and Huddle.