Missouri Court of Appeals, Western District / Jun 18, 2019
State of Missouri vs. Jeanne Capozzoli
Jeanne Capozzoli appealed her conviction for felony driving while intoxicated, raising two issues of first impression regarding a 2017 change in law concerning expert testimony. She argued that expert testimony on intoxication was prohibited as a "mental condition" under § 490.065.2(3)(b) and that the State failed to meet the Daubert standard for expert testimony under § 490.065.2(1)(c). The Western District affirmed, holding that intoxication is a physical, not mental, condition, and declined to address the Daubert challenge due to lack of prejudice from redundant testimony.