State v. Janson

In State v. Janson, 20 Conn. App. 348, 566 A.2d 1377 (1989), cert. denied, 213 Conn. 815, 569 A.2d 550 (1990) the Court ruled that, there being nothing in the record to indicate the identity of the person who drew the defendant's blood, the trial court improperly admitted into evidence the results of his blood test because the state had failed to satisfy the requirement of the statute that the blood be taken by a statutorily qualified person. State v. Janson, supra, 20 Conn. App. 352-53. The court stated that the "requirement directly promotes the underlying validity of the test itself and so must be strictly construed." Id., 352. In a footnote, the court distinguished Janson from other cases in which we liberally construed the terms of 14-227a (c) to admit into evidence tests that did not in all respects literally comply with subsection (c) requirements, so long as those requirements were in no way connected with promoting the underlying validity of the test. Id., 352 n.3.