People v. Foltz 

Defendant was convicted upon jury verdict of aggravated driving under the combined influence of alcohol and drugs. Insufficient evidence to prove that Defendant had any drugs in his system at time of arrest, as the only evidence of drug use presented at trial was that police officer smelled the odor of burnt cannabis in Defendant's vehicle. Officer lacked necessary experience to provide sufficient testimony that the Defendant was under the influence of drugs, as he had less than two years experience as an officer, this was his first arrest for DUI involving drugs, and he had no specific training in drug recognition. (WELCH and DONOVAN, concurring.)