☢ test - Í

Cunrod v. State, 241 Ga.App. 743, 526 S.E.2d 900 (December 14, 1999). Microscopic, thin layer chromatography, and Duquenois-Levine tests for identification of marijuana have been recognized in such substantial number of courts that state was not required to introduce evidence showing that scientific principles and techniques underlying such tests were valid and reliable. Accord, Cunrod v. State , 241 Ga.App. 743, 526 S.E.2d 900 (December 14, 1999); Trujillo v. State , 286 Ga.App. 438, 649 S.E.2d 573 (July 9, 2007). Kendrick v. State, 240 Ga.App. 530, 523 S.E.2d 414 (October 14, 1999). Physical precedent only. Revocation of defendant’s probation affirmed. “Under the controlling authority of Hubbard v. State, 207 Ga.App. 703, 704, 429 S.E.2d 123 (1993), the ontrack system for drug detection is not (yet) sufficiently recognized as reliable and so is not admissible evidence without expert testimony supporting its verifiable certainty. There was no such expert testimony in this case; although diversion center record was improperly admitted as a business record without adequate foundation, the reports of defendant’s cocaine and alcohol use were properly admitted because defendant signed them acknowledging the infractions, making them admissions against penal interest by a party. OCGA § 24-3-31.” See also Cheatwood (March 14, 2001), above, and cases cited thereunder. In re: J.L., 239 Ga.App. 766, 522 S.E.2d 239 (August 31, 1999). Finding of delinquency reversed; allegation that defendant tested positive for marijuana was not supported where “the test results were admitted into evidence by the juvenile court without any testimony or other foundation to support their admission.” Cook v. State, 270 Ga. 820, 514 S.E.2d 657 (March 19, 1999). Trial court properly refused to send out with jury “highly technical test result sheets” generated by State’s DNA expert, although they were admitted into evidence. “This ruling was not an abuse of discretion. Hicks v. State, 256 Ga. 715, 720(3), 352 S.E.2d 762 (1987) (trial court may exclude evidence if it could mislead or confuse jury).” Belton v. State , 270 Ga. 671, 512 S.E.2d 614 (February 22, 1999). Malice murder and related convictions affirmed; trial court properly allowed testimony by two witnesses “as experts in the identification of shoe prints.” Contrary to defendant’s argument, this evidence wasn’t subject to requirements of “ Harper v. State, 249 Ga. 519, 292 S.E.2d 389 (1982), that shoe print identification has reached a level of verifiable certainty. … [A]lthough the witnesses were presented as experts, it was apparent that their testimony did not deal with scientific principles but with observation and comparison of physical objects, with matters not of science but of skill and experience. See OCGA § 24–9–67.” “[T]he comparison of shoe prints to the external physical characteristics of particular shoes is not a matter of scientific principle or technique. Since Harper and its standards are not applicable to the testimony involved in this case, the trial court did not err in failing to apply it.” Analogized to Hawkins v. State, 223 Ga.App. 34(1), 476 S.E.2d 803 (1996) ( basic sobriety tests such as the walk and turn, leg left, and reciting alphabet are not scientific tests subject to Harper analysis, but rather “are physical dexterity exercises that common sense, common experience, and the ‘laws of nature’ show are performed less well after drinking alcohol.”). Hawkins v. State , 223 Ga.App. 34, 476 S.E.2d 803 (October 1, 1996). DUI and related convictions affirmed; contrary to defendant’s assertion, basic sobriety tests such as the walk and turn, leg left, and reciting alphabet are not scientific tests subject to Harper analysis, but rather “are physical dexterity exercises that common sense, common experience, and the ‘laws of nature’ show are performed less well after drinking alcohol. The screening of these gross motor skills is hardly the type of ‘scientific principle or technique’ to which Harper referred , and this Court will not hold these physical manifestations of impairment, which could be as obvious to the layperson as to the expert, to such a standard of admissibility. Harper, supra at 524, 292 S.E.2d 389; State v. Pastorini, 222 Ga.App. 316, 474 S.E.2d 122 (1996); Crawford v. City of Forest Park, 215 Ga.App. 234, 450 S.E.2d 237 (1994); accord Mendoza v. State, 196 Ga.App. 627, 630, 396 S.E.2d 576 (1990) (Deen, P. J., concurring specially). Appellant's contentions regarding the subjective nature of the evaluation of these tests would be fodder for cross-examination, but would not impact on the validity of the tests, themselves, in detecting impairment. Pastorini, supra. Thus, the trial court in the case sub judice did not err in allowing the officer to testify regarding these field sobriety tests without first requiring expert testimony as a foundation for admission.” 2. LAB SAMPLES, CHAIN OF CUSTODY Note: Chain of custody is unchanged in the 2013 evidence code. See OCGA § 24-9-901 et seq. McMillan v. State, 327 Ga.App. 269, 758 S.E.2d 332 (May 5, 2014). Cocaine trafficking conviction affirmed. Lab evidence was properly admitted despite police evidence custodian’s admission that she had stolen currency from