blood alcohol test (New Mexico) · Go Syfert
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blood alcohol test in New Mexico

32 New Mexico opinions name it 2 courts 1964–2025 3 in the last five years

The cases below were cited by New Mexico courts in a sentence that names this issue. Sides come from how each citing opinion treated the case (Syfertize flag on that citation), so a case can appear on both: that is where the law is contested. A red or yellow chip is the case's own overall treatment.

Followed or applied (24)

CaseFollowedCited
State v. Chavezgreen
nmctapp · 1981 · cited in 2 New Mexico opinions naming this issue, 2014–2015
2 sentences

2015In State v. Steele, we held that where a driver refused to provide a blood sample under the Implied Consent Act, a law enforcement officer could not obtain the sample using a search warrant because the Implied Consent Act afforded the defendant greater protection than the Fourth Amendment. 1979-NMCA-113 , ¶¶ 7-9, 93 N.M. 470 , 601 P.2d 440 ; see also State v. Chavez, 1981-NMCA-060 , ¶ 4, 96 N.M. 313 , 629 P.2d 1242 (explaining that in Steele, “[t]his Court held that the Legislature gave the defendant ' more protection than was afforded by the Constitution and that, after his refusal, the resul

2015In State v. Steele, we held that where a driver refused to provide a blood sample under the Implied Consent Act, a law enforcement officer could not obtain the sample using a search warrant because the Implied Consent Act afforded the defendant greater protection than the Fourth Amendment. 1979-NMCA-113 , ¶¶ 7-9, 93 N.M. 470 , 601 P.2d 440 ; see also State v. Chavez, 1981-NMCA-060 , ¶ 4, 96 N.M. 313 , 629 P.2d 1242 (explaining that in Steele, “[t]his Court held that the Legislature gave the defendant ' more protection than was afforded by the Constitution and that, after his refusal, the resul

22
Pruitt v. State, Department of Public Safety, Division of Motor Vehiclesgreen
alaska · 1992 · cited in 2 New Mexico opinions naming this issue, 1993–1993
2 sentences

1993See Pruitt 825 P.2d at 894 .

1993See Pruitt 825 P.2d at 894 .

22
State v. Caudillogreen
nmctapp · 2002 · cited in 2 New Mexico opinions naming this issue, 2007–2017
2 sentences

2017See, e.g., State v. Notah-Hunter, 2005-NMCA-074, ¶ 24 , 137 N.M. 597 , 15 113 P.3d 867 (holding that the evidence was sufficient to uphold a conviction for DWI 16 where the defendant smelled of alcohol, had slurred speech, admitted to drinking 17 alcohol, failed field sobriety tests and was driving erratically); State v. Caudillo, 2003- 18 NMCA-042, ¶ 8, 133 N.M. 468 , 64 P.3d 495 (stating that the evidence was sufficient 2 1 to establish impairment where the defendant was involved in an accident, smelled of 2 alcohol, admitted to having consumed beer, and refused to take a blood alcohol test)

2017See, e.g., State v. Notah-Hunter, 2005-NMCA-074, ¶ 24 , 137 N.M. 597 , 15 113 P.3d 867 (holding that the evidence was sufficient to uphold a conviction for DWI 16 where the defendant smelled of alcohol, had slurred speech, admitted to drinking 17 alcohol, failed field sobriety tests and was driving erratically); State v. Caudillo, 2003- 18 NMCA-042, ¶ 8, 133 N.M. 468 , 64 P.3d 495 (stating that the evidence was sufficient 2 1 to establish impairment where the defendant was involved in an accident, smelled of 2 alcohol, admitted to having consumed beer, and refused to take a blood alcohol test)

12
State v. Jonesgreen
nmctapp · 1998 · cited in 2 New Mexico opinions naming this issue, 2007–2010
2 sentences

2007In summary, Defendant argues that in most cases, the courts have required much more evidence than exists here to prove each element beyond a reasonable doubt. {33} Defendant relies on the following cases: Caudillo, 2003-NMCA-042, ¶ 8 (stating that the evidence was sufficient to support a conclusion that the defendant was impaired when the defendant was involved in an accident, admitted to having drunk a few beers, and refused to take a blood alcohol test and when the officers noticed slurred speech and a strong odor of alcohol); State v. Sanchez, 2001-NMCA-109, ¶¶ 15-16 , 131 N.M. 355 , 36 P.3

2007In summary, Defendant argues that in most cases, the courts have required much more evidence than exists here to prove each element beyond a reasonable doubt. {33} Defendant relies on the following cases: Caudillo, 2003-NMCA-042, ¶ 8 (stating that the evidence was sufficient to support a conclusion that the defendant was impaired when the defendant was involved in an accident, admitted to having drunk a few beers, and refused to take a blood alcohol test and when the officers noticed slurred speech and a strong odor of alcohol); State v. Sanchez, 2001-NMCA-109, ¶¶ 15-16 , 131 N.M. 355 , 36 P.3

12
State v. Sotogreen
nmctapp · 2007 · cited in 1 New Mexico opinions naming this issue, 2025–2025
1 sentence

2025See Soto, 2007-NMCA-077, ¶ 34 . {8} Based on the evidence discussed above, we conclude the State presented sufficient evidence to demonstrate that Defendant was impaired to the slightest degree, and therefore affirm Defendant’s conviction for aggravated DWI.

11
State v. Martinezgreen
nm · 2007 · cited in 1 New Mexico opinions naming this issue, 2020–2020
1 sentence

2020See Martinez, 2007-NMSC-025, ¶ 11 (reiterating Dedman’s holding that “to meet foundational requirements, the [s]tate does not need to show compliance with all regulations, but only with those that are ‘accuracy-ensuring’ ”). {28} By way of illustration, in Dedman, our Supreme Court considered whether the defendant’s blood test results lacked the proper foundation, where the state failed to prove that the defendant’s blood-alcohol test had been administered via venipuncture, as required by 7.33.2.15(A)(1) NMAC.

11
State v. Dedmangreen
nm · 2004 · cited in 1 New Mexico opinions naming this issue, 2020–2020
1 sentence

2020See Dedman, 2004-NMSC-037, ¶¶ 4-6 . 2 Examining various methods for drawing blood (including venipuncture, arterial puncture, and skin puncture), our Supreme Court concluded that “the reason for collection through veni[]puncture is not a higher probability of accuracy.

11
State v. Notah-Huntergreen
nmctapp · 2005 · cited in 1 New Mexico opinions naming this issue, 2017–2017
2 sentences

2017See, e.g., State v. Notah-Hunter, 2005-NMCA-074, ¶ 24 , 137 N.M. 597 , 15 113 P.3d 867 (holding that the evidence was sufficient to uphold a conviction for DWI 16 where the defendant smelled of alcohol, had slurred speech, admitted to drinking 17 alcohol, failed field sobriety tests and was driving erratically); State v. Caudillo, 2003- 18 NMCA-042, ¶ 8, 133 N.M. 468 , 64 P.3d 495 (stating that the evidence was sufficient 2 1 to establish impairment where the defendant was involved in an accident, smelled of 2 alcohol, admitted to having consumed beer, and refused to take a blood alcohol test)

2017See, e.g., State v. Notah-Hunter, 2005-NMCA-074, ¶ 24 , 137 N.M. 597 , 15 113 P.3d 867 (holding that the evidence was sufficient to uphold a conviction for DWI 16 where the defendant smelled of alcohol, had slurred speech, admitted to drinking 17 alcohol, failed field sobriety tests and was driving erratically); State v. Caudillo, 2003- 18 NMCA-042, ¶ 8, 133 N.M. 468 , 64 P.3d 495 (stating that the evidence was sufficient 2 1 to establish impairment where the defendant was involved in an accident, smelled of 2 alcohol, admitted to having consumed beer, and refused to take a blood alcohol test)

11
State v. Rowellgreen
nm · 2008 · cited in 1 New Mexico opinions naming this issue, 2016–2016
1 sentence

2016Our Supreme Court has stated that “[a]ny warrantless search 6 analysis must start with the bedrock principle of both federal and state constitutional 7 jurisprudence that searches conducted outside the judicial process, without prior 8 approval by judge or magistrate, are per se unreasonable, subject only to well- 9 delineated exceptions.” Rowell, 2008-NMSC-041, ¶ 10 (internal quotation marks and 10 citation omitted). 11 {19} A blood alcohol test is considered “a search of ‘persons’ [,]” and therefore falls 12 within the ambit of the Fourth Amendment.

11
State v. Purkgreen
nmctapp · 1973 · cited in 1 New Mexico opinions naming this issue, 2012–2012
1 sentence

2012See State v. Purk, 84 N.M. 6 668, 669, 506 P.2d 1215, 1216 (Ct. App. 1973). 7 “[I]t is error to admit expert testimony involving scientific knowledge unless 8 the party offering such testimony first establishes the evidentiary reliability of the 9 scientific knowledge.” State v. Torres, 1999-NMSC-010, ¶ 24 , 127 N.M. 20 , 976 P.2d 10 20.

11
State v. Torresgreen
nm · 1999 · cited in 1 New Mexico opinions naming this issue, 2012–2012
2 sentences

2012See State v. Purk, 84 N.M. 6 668, 669, 506 P.2d 1215, 1216 (Ct. App. 1973). 7 “[I]t is error to admit expert testimony involving scientific knowledge unless 8 the party offering such testimony first establishes the evidentiary reliability of the 9 scientific knowledge.” State v. Torres, 1999-NMSC-010, ¶ 24 , 127 N.M. 20 , 976 P.2d 10 20.

2012See State v. Purk, 84 N.M. 6 668, 669, 506 P.2d 1215, 1216 (Ct. App. 1973). 7 “[I]t is error to admit expert testimony involving scientific knowledge unless 8 the party offering such testimony first establishes the evidentiary reliability of the 9 scientific knowledge.” State v. Torres, 1999-NMSC-010, ¶ 24 , 127 N.M. 20 , 976 P.2d 10 20.

11
State v. Gonzalesred
nm · 1992 · cited in 1 New Mexico opinions naming this issue, 2008–2008
2 sentences

2008See State v. Gonzales, 113 N.M. 221, 229 , 824 P.2d 1023, 1031 (1992); Foster, 1998-NMCA-163 , ¶¶ 13-14.

2008See State v. Gonzales, 113 N.M. 221, 229 , 824 P.2d 1023, 1031 (1992); Foster, 1998-NMCA-163 , ¶¶ 13-14.

11
State v. Hernandezgreen
nmctapp · 1980 · cited in 1 New Mexico opinions naming this issue, 2007–2007
2 sentences

2007In summary, Defendant argues that in most cases, the courts have required much more evidence than exists here to prove each element beyond a reasonable doubt. {33} Defendant relies on the following cases: Caudillo, 2003-NMCA-042, ¶ 8 (stating that the evidence was sufficient to support a conclusion that the defendant was impaired when the defendant was involved in an accident, admitted to having drunk a few beers, and refused to take a blood alcohol test and when the officers noticed slurred speech and a strong odor of alcohol); State v. Sanchez, 2001-NMCA-109, ¶¶ 15-16 , 131 N.M. 355 , 36 P.3

2007In summary, Defendant argues that in most cases, the courts have required much more evidence than exists here to prove each element beyond a reasonable doubt. {33} Defendant relies on the following cases: Caudillo, 2003-NMCA-042, ¶ 8 (stating that the evidence was sufficient to support a conclusion that the defendant was impaired when the defendant was involved in an accident, admitted to having drunk a few beers, and refused to take a blood alcohol test and when the officers noticed slurred speech and a strong odor of alcohol); State v. Sanchez, 2001-NMCA-109, ¶¶ 15-16 , 131 N.M. 355 , 36 P.3

11
State v. Ruizgreen
nmctapp · 1995 · cited in 1 New Mexico opinions naming this issue, 2007–2007
2 sentences

2007In summary, Defendant argues that in most cases, the courts have required much more evidence than exists here to prove each element beyond a reasonable doubt. {33} Defendant relies on the following cases: Caudillo, 2003-NMCA-042, ¶ 8 (stating that the evidence was sufficient to support a conclusion that the defendant was impaired when the defendant was involved in an accident, admitted to having drunk a few beers, and refused to take a blood alcohol test and when the officers noticed slurred speech and a strong odor of alcohol); State v. Sanchez, 2001-NMCA-109, ¶¶ 15-16 , 131 N.M. 355 , 36 P.3

2007In summary, Defendant argues that in most cases, the courts have required much more evidence than exists here to prove each element beyond a reasonable doubt. {33} Defendant relies on the following cases: Caudillo, 2003-NMCA-042, ¶ 8 (stating that the evidence was sufficient to support a conclusion that the defendant was impaired when the defendant was involved in an accident, admitted to having drunk a few beers, and refused to take a blood alcohol test and when the officers noticed slurred speech and a strong odor of alcohol); State v. Sanchez, 2001-NMCA-109, ¶¶ 15-16 , 131 N.M. 355 , 36 P.3

11
State v. Suazogreen
nm · 1994 · cited in 1 New Mexico opinions naming this issue, 1999–1999
1 sentence

1999See In re Suazo, 117 N.M. at 786 , 877 P.2d at 1089 .

11
Matter of Suazogreen
nm · 1994 · cited in 1 New Mexico opinions naming this issue, 1999–1999
11
State v. Wrightgreen
nmctapp · 1972 · cited in 1 New Mexico opinions naming this issue, 1998–1998
11
City of Portales v. Shiplettgreen
nm · 1960 · cited in 1 New Mexico opinions naming this issue, 1998–1998
11
State v. Corradogreen
njsuperctappdiv · 1982 · cited in 1 New Mexico opinions naming this issue, 1994–1994
11
State v. Taylorgreen
nh · 1989 · cited in 1 New Mexico opinions naming this issue, 1992–1992
11
Desmond v. Superior Courtgreen
ariz · 1989 · cited in 1 New Mexico opinions naming this issue, 1992–1992
11
Purchase v. Meyergreen
wash · 1987 · cited in 1 New Mexico opinions naming this issue, 1992–1992
11
State v. Copelandgreen
nmctapp · 1986 · cited in 1 New Mexico opinions naming this issue, 1991–1991
11
State v. Wetherellgreen
wash · 1973 · cited in 1 New Mexico opinions naming this issue, 1975–1975
11

Distinguished, questioned or overruled (0)

CaseNegativeCited
No negative-treatment citations attached to this issue in New Mexico. Read the followed side critically anyway.

Also cited on this issue (33)

CaseCitedYears
State v. Richerson green
nmctapp · 1975
2 sentences

2016State v. Richerson, 1975-NMCA-027 , 13 ¶ 23, 87 N.M. 437 , 535 P.2d 644 .

2016State v. Richerson, 1975-NMCA-027 , 13 ¶ 23, 87 N.M. 437 , 535 P.2d 644 .

21988–2016
State v. Steele green
nmctapp · 1979
2 sentences

2015In State v. Steele, we held that where a driver refused to provide a blood sample under the Implied Consent Act, a law enforcement officer could not obtain the sample using a search warrant because the Implied Consent Act afforded the defendant greater protection than the Fourth Amendment. 1979-NMCA-113 , ¶¶ 7-9, 93 N.M. 470 , 601 P.2d 440 ; see also State v. Chavez, 1981-NMCA-060 , ¶ 4, 96 N.M. 313 , 629 P.2d 1242 (explaining that in Steele, “[t]his Court held that the Legislature gave the defendant ' more protection than was afforded by the Constitution and that, after his refusal, the resul

2015In State v. Steele, we held that where a driver refused to provide a blood sample under the Implied Consent Act, a law enforcement officer could not obtain the sample using a search warrant because the Implied Consent Act afforded the defendant greater protection than the Fourth Amendment. 1979-NMCA-113 , ¶¶ 7-9, 93 N.M. 470 , 601 P.2d 440 ; see also State v. Chavez, 1981-NMCA-060 , ¶ 4, 96 N.M. 313 , 629 P.2d 1242 (explaining that in Steele, “[t]his Court held that the Legislature gave the defendant ' more protection than was afforded by the Constitution and that, after his refusal, the resul

22014–2015
Bullcoming v. New Mexico green
scotus · 2011
2 sentences

2012Thereafter, the United States Supreme Court in Bullcoming v. New Mexico, 131 S.Ct. 2705 (2011), implicitly rejected the distinction between chemical analyses and blood alcohol tests and held that the testimony of a substitute expert about a blood alcohol analysis report conducted by another analyst violated the defendant’s confrontation rights.

2011Cooper, Acting Chief Public Defender 19 Susan Roth, Assistant Appellate Defender 20 Santa Fe, NM 21 for Appellant 22 MEMORANDUM OPINION 23 SUTIN, Judge. 1 Defendant Joseph Marez appeals from the judgment and sentence, following 2 a jury trial, convicting him of driving while intoxicated (DWI) (.08 or above). [RP 3 106] Defendant contends that his confrontation rights were violated when the district 4 court allowed the supervisor of the person who actually conducted the blood test and 5 prepared the Scientific Laboratory Division (SLD) report to give his expert opinion 6 at trial as to the bloo

22011–2012
Bierner v. State, Taxation & Revenue Department green
nmctapp · 1992
2 sentences

1993We added, "[T]he legislature could properly decide that it did not want hearings prolonged by the testimony of experts and other witnesses that may be necessary to connect the blood alcohol test result with the licensee's BAC at the time he or she was driving." Id.

1993We added, “[T]he legislature could properly decide that it did not want hearings prolonged by the testimony of experts and other witnesses that may be necessary to connect the blood alcohol test result with the licensee’s BAC at the time he or she was driving.” Id.

21993–1993
State v. Gardner green
nmctapp · 1998
2 sentences

2023In Gardner, we held that the numerical breath test results were improperly admitted into evidence and concluded that “when the only scientific evidence presented at trial was admitted in error, the court cannot say that the effect is harmless.” 1998-NMCA-160, ¶¶ 20-21 . {14} Unlike in Franklin, in which the district court announced the blood alcohol test results during its verdict and expressed concern, the metropolitan court in the present case did not rely on—or even mention—the breath card when delivering the verdict. 2 While, like in Gardner, the breath tests results were the “only scienti

2023In Gardner, we held that the numerical breath test results were improperly admitted into evidence and concluded that “when the only scientific evidence presented at trial was admitted in error, the court cannot say that the effect is harmless.” 1998-NMCA-160, ¶¶ 20-21 . {14} Unlike in Franklin, in which the district court announced the blood alcohol test results during its verdict and expressed concern, the metropolitan court in the present case did not rely on—or even mention—the breath card when delivering the verdict. 2 While, like in Gardner, the breath tests results were the “only scienti

12023–2023
State v. Franklin green
nmctapp · 2019
2 sentences

2021Officer Cobb is not, and he can’t testify as to the credentials of those people who took the blood.” The district court overruled the objection. {27} Assuming without deciding that Defendant preserved the issue he now raises on appeal and the district court erred in admitting the results of the blood draw, but see State v. Franklin, 2020-NMCA-016, ¶ 24 , 460 P.3d 69 (stating that the individual who performed the blood draw is not required to testify and the necessary foundation may be established by an officer who witnessed the blood draw), we review Defendant’s claim for harmless error.

2021Officer Cobb is not, and he can’t testify as to the credentials of those people who took the blood.” The district court overruled the objection. {27} Assuming without deciding that Defendant preserved the issue he now raises on appeal and the district court erred in admitting the results of the blood draw, but see State v. Franklin, 2020-NMCA-016, ¶ 24 , 460 P.3d 69 (stating that the individual who performed the blood draw is not required to testify and the necessary foundation may be established by an officer who witnessed the blood draw), we review Defendant’s claim for harmless error.

12021–2021
State v. Estrada green
nmctapp · 2001
2 sentences

2017See, e.g., State v. Notah-Hunter, 2005-NMCA-074, ¶ 24 , 137 N.M. 597 , 15 113 P.3d 867 (holding that the evidence was sufficient to uphold a conviction for DWI 16 where the defendant smelled of alcohol, had slurred speech, admitted to drinking 17 alcohol, failed field sobriety tests and was driving erratically); State v. Caudillo, 2003- 18 NMCA-042, ¶ 8, 133 N.M. 468 , 64 P.3d 495 (stating that the evidence was sufficient 2 1 to establish impairment where the defendant was involved in an accident, smelled of 2 alcohol, admitted to having consumed beer, and refused to take a blood alcohol test)

2017See, e.g., State v. Notah-Hunter, 2005-NMCA-074, ¶ 24 , 137 N.M. 597 , 15 113 P.3d 867 (holding that the evidence was sufficient to uphold a conviction for DWI 16 where the defendant smelled of alcohol, had slurred speech, admitted to drinking 17 alcohol, failed field sobriety tests and was driving erratically); State v. Caudillo, 2003- 18 NMCA-042, ¶ 8, 133 N.M. 468 , 64 P.3d 495 (stating that the evidence was sufficient 2 1 to establish impairment where the defendant was involved in an accident, smelled of 2 alcohol, admitted to having consumed beer, and refused to take a blood alcohol test)

12017–2017
State v. Baldwin green
nmctapp · 2001
2 sentences

2015While Jones does not inform us on what basis 18 these statements were made, it is well settled that such questions are matters of 19 scientific expertise, and constitute adjudicative facts not subject to judicial notice. 18 1 See State v. Day, 2008-NMSC-007, ¶ 31 , 143 N.M. 359 , 176 P.3d 1091 (discussing 2 the necessity of use of scientific retrograde extrapolation evidence to determine BAC 3 at an earlier time); State v. Baldwin, 2001-NMCA-063, ¶ 17 , 130 N.M. 705 , 30 P.3d 4 394 (“But a BAC reading from a laboratory test is just a sterile number; by itself it 5 tells us nothing about a driv

2015While Jones does not inform us on what basis 18 these statements were made, it is well settled that such questions are matters of 19 scientific expertise, and constitute adjudicative facts not subject to judicial notice. 18 1 See State v. Day, 2008-NMSC-007, ¶ 31 , 143 N.M. 359 , 176 P.3d 1091 (discussing 2 the necessity of use of scientific retrograde extrapolation evidence to determine BAC 3 at an earlier time); State v. Baldwin, 2001-NMCA-063, ¶ 17 , 130 N.M. 705 , 30 P.3d 4 394 (“But a BAC reading from a laboratory test is just a sterile number; by itself it 5 tells us nothing about a driv

12015–2015
State v. Day green
nm · 2008
2 sentences

2015While Jones does not inform us on what basis 18 these statements were made, it is well settled that such questions are matters of 19 scientific expertise, and constitute adjudicative facts not subject to judicial notice. 18 1 See State v. Day, 2008-NMSC-007, ¶ 31 , 143 N.M. 359 , 176 P.3d 1091 (discussing 2 the necessity of use of scientific retrograde extrapolation evidence to determine BAC 3 at an earlier time); State v. Baldwin, 2001-NMCA-063, ¶ 17 , 130 N.M. 705 , 30 P.3d 4 394 (“But a BAC reading from a laboratory test is just a sterile number; by itself it 5 tells us nothing about a driv

2015While Jones does not inform us on what basis 18 these statements were made, it is well settled that such questions are matters of 19 scientific expertise, and constitute adjudicative facts not subject to judicial notice. 18 1 See State v. Day, 2008-NMSC-007, ¶ 31 , 143 N.M. 359 , 176 P.3d 1091 (discussing 2 the necessity of use of scientific retrograde extrapolation evidence to determine BAC 3 at an earlier time); State v. Baldwin, 2001-NMCA-063, ¶ 17 , 130 N.M. 705 , 30 P.3d 4 394 (“But a BAC reading from a laboratory test is just a sterile number; by itself it 5 tells us nothing about a driv

12015–2015
Melendez-Diaz v. Massachusetts green
scotus · 2009
1 sentence

2011Cooper, Acting Chief Public Defender 19 Susan Roth, Assistant Appellate Defender 20 Santa Fe, NM 21 for Appellant 22 MEMORANDUM OPINION 23 SUTIN, Judge. 1 Defendant Joseph Marez appeals from the judgment and sentence, following 2 a jury trial, convicting him of driving while intoxicated (DWI) (.08 or above). [RP 3 106] Defendant contends that his confrontation rights were violated when the district 4 court allowed the supervisor of the person who actually conducted the blood test and 5 prepared the Scientific Laboratory Division (SLD) report to give his expert opinion 6 at trial as to the bloo

12011–2011
State v. Bullcoming green
nm · 2010
2 sentences

2011Cooper, Acting Chief Public Defender 19 Susan Roth, Assistant Appellate Defender 20 Santa Fe, NM 21 for Appellant 22 MEMORANDUM OPINION 23 SUTIN, Judge. 1 Defendant Joseph Marez appeals from the judgment and sentence, following 2 a jury trial, convicting him of driving while intoxicated (DWI) (.08 or above). [RP 3 106] Defendant contends that his confrontation rights were violated when the district 4 court allowed the supervisor of the person who actually conducted the blood test and 5 prepared the Scientific Laboratory Division (SLD) report to give his expert opinion 6 at trial as to the bloo

2011Cooper, Acting Chief Public Defender 19 Susan Roth, Assistant Appellate Defender 20 Santa Fe, NM 21 for Appellant 22 MEMORANDUM OPINION 23 SUTIN, Judge. 1 Defendant Joseph Marez appeals from the judgment and sentence, following 2 a jury trial, convicting him of driving while intoxicated (DWI) (.08 or above). [RP 3 106] Defendant contends that his confrontation rights were violated when the district 4 court allowed the supervisor of the person who actually conducted the blood test and 5 prepared the Scientific Laboratory Division (SLD) report to give his expert opinion 6 at trial as to the bloo

12011–2011
State v. Foster green
nmctapp · 1998
1 sentence

2008See State v. Gonzales, 113 N.M. 221, 229 , 824 P.2d 1023, 1031 (1992); Foster, 1998-NMCA-163 , ¶¶ 13-14.

12008–2008
State v. Sanchez green
nmctapp · 2001
2 sentences

2007In summary, Defendant argues that in most cases, the courts have required much more evidence than exists here to prove each element beyond a reasonable doubt. {33} Defendant relies on the following cases: Caudillo, 2003-NMCA-042, ¶ 8 (stating that the evidence was sufficient to support a conclusion that the defendant was impaired when the defendant was involved in an accident, admitted to having drunk a few beers, and refused to take a blood alcohol test and when the officers noticed slurred speech and a strong odor of alcohol); State v. Sanchez, 2001-NMCA-109, ¶¶ 15-16 , 131 N.M. 355 , 36 P.3

2007In summary, Defendant argues that in most cases, the courts have required much more evidence than exists here to prove each element beyond a reasonable doubt. {33} Defendant relies on the following cases: Caudillo, 2003-NMCA-042, ¶ 8 (stating that the evidence was sufficient to support a conclusion that the defendant was impaired when the defendant was involved in an accident, admitted to having drunk a few beers, and refused to take a blood alcohol test and when the officers noticed slurred speech and a strong odor of alcohol); State v. Sanchez, 2001-NMCA-109, ¶¶ 15-16 , 131 N.M. 355 , 36 P.3

12007–2007
State v. Christian green
nmctapp · 1995
2 sentences

2004She further testified that the blood kit’s seals were intact, she signed her name as the receiving employee, and she performed the blood alcohol test on Defendant’s blood. {42} Reliability “is said variously to be supplied by systematic checking, by regularity and continuity which produce habits of precision, by actual experience of business in relying upon them, or by a duty to make an accurate record as part of a continuing job or occupation.” Christian, 119 N.M. at 779 , 895 P.2d at 679 (quoting Fed.R.Evid. 803 advisory committee’s note).

2004She further testified that the blood kit’s seals were intact, she signed her name as the receiving employee, and she performed the blood alcohol test on Defendant’s blood. {42} Reliability “is said variously to be supplied by systematic checking, by regularity and continuity which produce habits of precision, by actual experience of business in relying upon them, or by a duty to make an accurate record as part of a continuing job or occupation.” Christian, 119 N.M. at 779 , 895 P.2d at 679 (quoting Fed.R.Evid. 803 advisory committee’s note).

12004–2004
State Ex Rel. Schwartz v. Kennedy green
nm · 1995
2 sentences

2002(Kennedy, 120 N.M. at 631 , 904 P.2d at 1056 ) (“[W]hether a sanction constitutes punishment is not determined from the defendant’s perspective, as even remedial sanctions carry the sting of punishment.”) (quoted authority and quotation marks omitted). {12} In Kennedy, this Court determined that suspending the driver’s license of an individual who exceeded the statutory limits of a blood-alcohol test or refused to take the test “serves the legitimate nonpunitive purpose of protecting the public from the dangers presented by drank drivers and helps enforce regulatory compliance with the laws go

2002(Kennedy, 120 N.M. at 631 , 904 P.2d at 1056 ) (“[W]hether a sanction constitutes punishment is not determined from the defendant’s perspective, as even remedial sanctions carry the sting of punishment.”) (quoted authority and quotation marks omitted). {12} In Kennedy, this Court determined that suspending the driver’s license of an individual who exceeded the statutory limits of a blood-alcohol test or refused to take the test “serves the legitimate nonpunitive purpose of protecting the public from the dangers presented by drank drivers and helps enforce regulatory compliance with the laws go

12002–2002
State v. Bearly green
nmctapp · 1991
11998–1998
South Dakota v. Neville green
scotus · 1983
11997–1997
State v. Geisler green
connappct · 1990
11992–1992
State v. Larson green
minnctapp · 1988
11992–1992
State v. Kubik green
neb · 1990
11992–1992
State v. Dumont green
vt · 1985
11992–1992
State v. Ladwig green
sd · 1989
11992–1992
Haas v. State green
fladistctapp · 1990
11992–1992
Ledsome v. U-Brand Corp. green
scotus · 1991
11992–1992
Ransford v. District of Columbia green
dc · 1990
11992–1992
State v. Wyrostek green
nmctapp · 1988
11991–1991
Cave v. Cooley green
nm · 1944
11978–1978
Breithaupt v. Abram green
nm · 1954
11964–1964
State v. Stoesser green
delsuperct · 1962
11964–1964
Breithaupt v. Abram green
scotus · 1957
11964–1964
People v. Conterno green
calctapp · 1959
11964–1964
Machado v. New York green
scotus · 1963
11964–1964
Commonwealth v. Tanchyn green
pasuperct · 1963
11964–1964

Statutes the citing opinions construe

NM § N.M. Stat. § 66-8-102 (13) NM § N.M. Stat. § 66-8-105 (13) NM § N.M. Stat. § 66-8-107 (12) NM § N.M. Stat. § 66-8-111 (7) NM § N.M. Stat. § 66-8-110 (6) NM § N.M. Stat. § 66-8-112 (5) NM § N.M. Stat. § 66-8-108 (4) NM § N.M. Stat. § 66-8-109 (4) NM § N.M. Stat. § 24-1-22 (3) NM § N.M. Stat. § 66-8-101 (3)

Counted by distinct opinions that both name this issue and are annotated to the section; sections every opinion cites regardless of issue are not filtered here, so read the counts against the total above.

Where else courts name it

PA 131 (1970–2026) TX 130 (1961–2026) FL 102 (1967–2023) GA 95 (1966–2025) IL 94 (1972–2024) CA 85 (1960–2024) MO 83 (1968–2024) OH 75 (1973–2025) NY 66 (1970–2023) WA 56 (1975–2024) ND 52 (1980–2020) TN 51 (1975–2025) LA 50 (1976–2021) CO 48 (1946–2024) ME 48 (1969–2025) KS 47 (1966–2024) ID 46 (1971–2025) MI 45 (1975–2025) MN 44 (1975–2015) OR 40 (1973–2026) AL 39 (1980–2015) NM 32 (1964–2025) AZ 31 (1967–2020) MA 28 (1984–2023) MS 28 (1984–2024) VA 25 (1966–2019) WI 25 (1977–2024) CT 23 (1988–2026) MT 21 (1971–2024) MD 20 (1984–2022) NJ 18 (1965–2021) KY 18 (1971–2025) NH 18 (1984–2020) NC 17 (1973–2026) IN 15 (1976–2016) IA 15 (1973–2021) WY 14 (1968–2022) OK 14 (1973–2014) HI 14 (1995–2020) SD 13 (1969–2022) NE 12 (1977–2020) AK 11 (1974–2001) SC 11 (1990–2014) VT 11 (1965–2024) AR 10 (1988–2015) UT 8 (1979–2009) NV 7 (1969–2013) WV 7 (1980–2021) DE 7 (1973–2019) RI 6 (1984–2004) DC 4 (1983–2001)

Opinions by the citing court's state. A doctrine retained in one state and abandoned in another shows up here as a year span that stalls.

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