BAC test (Illinois) · Go Syfert
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BAC test in Illinois

20 Illinois opinions name it 2 courts 1999–2025 4 in the last five years

The cases below were cited by Illinois 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 (9)

CaseFollowedCited
Missouri v. McNeelygreen
scotus · 2013 · cited in 6 Illinois opinions naming this issue, 2014–2021
2 sentences

2019A plurality of the Supreme Court, when deciding the constitutionality of the blood draw, did not answer the broader question of the constitutionality of implied consent laws but, rather, answered the narrower question of “ ‘[w]hether a statute authorizing a blood draw from an unconscious motorist provides an exception to the Fourth Amendment warrant requirement.’ ” Id. at ___ n.5, 139 S. Ct. at 2546 n.5. ¶ 109 The Mitchell plurality first reaffirmed that a warrantless BAC test may not be legally obtained when the only exigency is dissipation of alcohol in the blood. - 43 - Rather, the pluralit

2016Ct. App. 1985); State v. Milligan, 748 P.2d 130, 136 (Or. 1988) (en banc); see also McNeely, 569 U.S. at ___ , 133 S. Ct. at 1575-76 (Thomas, J., dissenting) (defending the per se rule by analogizing Schmerber and Cupp). ¶ 22 In Todd, in consolidated cases, our supreme court affirmed the suppression of BAC test results derived from warrantless, nonconsensual blood draws taken from hospitalized DUI suspects at the direction of law enforcement.

46
Village of Bull Valley, Illinois v. Winterpachtgreen
illappct · 2012 · cited in 2 Illinois opinions naming this issue, 2021–2022
2 sentences

2022See Winterpacht, 2012 IL App (2d) 101192, ¶ 13 (holding that, when a BAC test result is above the statutory limit and “a reasonable amount of time elapses between when the defendant was driving and the test, extrapolation evidence is permissible but is not a foundational requirement”); Torruella, 2015 IL App (2d) 141001, ¶¶ 41-42 (same).

2022See Winterpacht, 2012 IL App (2d) 101192, ¶ 13 (holding that, when a BAC test result is above the statutory limit and “a reasonable amount of time elapses between when the defendant was driving and the test, extrapolation evidence is permissible but is not a foundational requirement”); Torruella, 2015 IL App (2d) 141001, ¶¶ 41-42 (same).

22
People v. Torruellagreen
illappct · 2015 · cited in 2 Illinois opinions naming this issue, 2021–2022
2 sentences

2022See Winterpacht, 2012 IL App (2d) 101192, ¶ 13 (holding that, when a BAC test result is above the statutory limit and “a reasonable amount of time elapses between when the defendant was driving and the test, extrapolation evidence is permissible but is not a foundational requirement”); Torruella, 2015 IL App (2d) 141001, ¶¶ 41-42 (same).

2022See Winterpacht, 2012 IL App (2d) 101192, ¶ 13 (holding that, when a BAC test result is above the statutory limit and “a reasonable amount of time elapses between when the defendant was driving and the test, extrapolation evidence is permissible but is not a foundational requirement”); Torruella, 2015 IL App (2d) 141001, ¶¶ 41-42 (same).

22
Schmerber v. Californiagreen
scotus · 1966 · cited in 2 Illinois opinions naming this issue, 2019–2021
2 sentences

2021Rather, the plurality held, “exigency exists when (1) BAC evidence is dissipating and (2) some other factor creates pressing health, safety, or law enforcement needs that would take priority over a warrant application.” Id. at ___, 139 S. Ct. at 2537 ; see Schmerber v. California, 384 U.S. 757, 770 (1996); Missouri v. McNeely, 569 U.S. 141, 150-51 (2013).

2019A plurality of the Supreme Court, when deciding the constitutionality of the blood draw, did not answer the broader question of the constitutionality of implied consent laws but, rather, answered the narrower question of “ ‘[w]hether a statute authorizing a blood draw from an unconscious motorist provides an exception to the Fourth Amendment warrant requirement.’ ” Id. at ___ n.5, 139 S. Ct. at 2546 n.5. ¶ 109 The Mitchell plurality first reaffirmed that a warrantless BAC test may not be legally obtained when the only exigency is dissipation of alcohol in the blood. - 43 - Rather, the pluralit

22
State v. Milligangreen
or · 1988 · cited in 2 Illinois opinions naming this issue, 2016–2016
2 sentences

2016Ct. App. 1985); State v. Milligan, 748 P.2d 130, 136 (Or. 1988) (en banc); see also McNeely, 569 U.S. at ___ , 133 S. Ct. at 1575-76 (Thomas, J., dissenting) (defending the per se rule by analogizing Schmerber and Cupp). ¶ 22 In Todd, in consolidated cases, our supreme court affirmed the suppression of BAC test results derived from warrantless, nonconsensual blood draws taken from hospitalized DUI suspects at the direction of law enforcement.

2016Ct. App. 1985); State v. Milligan, 748 P.2d 130, 136 (Or. 1988) (en banc); see also McNeely, 569 U.S. at ___ , 133 S. Ct. at 1575-76 (Thomas, J., dissenting) (defending the per se rule by analogizing Schmerber and Cupp). ¶ 22 In Todd, in consolidated cases, our supreme court affirmed the suppression of BAC test results derived from warrantless, nonconsensual blood draws taken from hospitalized DUI suspects at the direction of law enforcement.

22
People v. Emrichgreen
ill · 1986 · cited in 2 Illinois opinions naming this issue, 2011–2011
2 sentences

2011People v. Murphy, 108 Ill.2d 228, 236 , 91 Ill.Dec. 653 , 483 N.E.2d 1288 (1985); see also Emrich, 113 Ill.2d at 351 , 101 Ill.Dec. 632 , 498 N.E.2d 1140 (both involving the offense of reckless homicide).

2011People v. Murphy, 108 Ill.2d 228, 236 , 91 Ill.Dec. 653 , 483 N.E.2d 1288 (1985); see also Emrich, 113 Ill.2d at 351 , 101 Ill.Dec. 632 , 498 N.E.2d 1140 (both involving the offense of reckless homicide).

22
People v. Murphygreen
ill · 1985 · cited in 2 Illinois opinions naming this issue, 2011–2011
2 sentences

2011People v. Murphy, 108 Ill.2d 228, 236 , 91 Ill.Dec. 653 , 483 N.E.2d 1288 (1985); see also Emrich, 113 Ill.2d at 351 , 101 Ill.Dec. 632 , 498 N.E.2d 1140 (both involving the offense of reckless homicide).

2011People v. Murphy, 108 Ill.2d 228, 236 , 91 Ill.Dec. 653 , 483 N.E.2d 1288 (1985); see also Emrich, 113 Ill.2d at 351 , 101 Ill.Dec. 632 , 498 N.E.2d 1140 (both involving the offense of reckless homicide).

12
People v. Bushgreen
ill · 2005 · cited in 1 Illinois opinions naming this issue, 2025–2025
1 sentence

2025Our supreme court has held that “when a defendant procures, invites, or acquiesces in the admission of evidence, even though the evidence is improper, he cannot contest the admission on appeal.” People v. Bush, 214 Ill. 2d 318, 332 (2005).

11
People v. Watkinsgreen
illappct · 2019 · cited in 1 Illinois opinions naming this issue, 2020–2020
2 sentences

2020See People v. Watkins, 2019 IL App (4th) 180605, ¶ 39 , reh'g denied (Nov. 6, 2019).

2020See People v. Watkins, 2019 IL App (4th) 180605, ¶ 39 , reh'g denied (Nov. 6, 2019).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (14)

CaseCitedYears
Mitchell v. Wisconsin green
scotus · 2019
2 sentences

2021A plurality of the Supreme Court, when deciding the constitutionality of the blood draw, did not answer the broader question of the constitutionality of implied consent laws but, rather, answered the narrower question of “ ‘[w]hether a statute authorizing a blood draw from an unconscious motorist provides an exception to the Fourth Amendment warrant requirement.’ ” Id. at ___ n.5, 139 S. Ct. at 2546 n.5. ¶ 109 The Mitchell plurality first reaffirmed that a warrantless BAC test may not be legally obtained when the only exigency is dissipation of alcohol in the blood.

2021A plurality of the Supreme Court, when deciding the constitutionality of the blood draw, did not answer the broader question of the constitutionality of implied consent laws but, rather, answered the narrower question of “ ‘[w]hether a statute authorizing a blood draw from an unconscious motorist provides an exception to the Fourth Amendment warrant requirement.’ ” Id. at ___ n.5, 139 S. Ct. at 2546 n.5. ¶ 109 The Mitchell plurality first reaffirmed that a warrantless BAC test may not be legally obtained when the only exigency is dissipation of alcohol in the blood.

22019–2021
People v. Floyd green
illappct · 2014
2 sentences

2021However, relying on People v. Floyd, 2014 IL App (2d) 120507 , the court found that, because retrograde extrapolation would be inherently unreliable, the prejudicial effect of the BAC test result substantially outweighed any probative value.

2021However, relying on People v. Floyd, 2014 IL App (2d) 120507 , the court found that, because retrograde extrapolation would be inherently unreliable, the prejudicial effect of the BAC test result substantially outweighed any probative value.

22014–2021
People v. Todd green
ill · 1975
2 sentences

2016Todd, 59 Ill. 2d at 536-46 .

2016Todd, 59 Ill. 2d at 536-46 .

22016–2016
State v. Eighth Judicial District Court ex rel. County of Clark green
nev · 2011
2 sentences

2014Turning to the case before it, the Nevada Supreme Court noted that experts calculated the defendant’s BAC on factors attributed to the “average person” and “various hypothetical situations.” Id.

2014Turning to the case before it, the Nevada Supreme Court noted that experts calculated the defendant’s BAC on factors attributed to the “average person” and “various hypothetical situations.” Id.

22014–2014
People v. Ethridge green
illappct · 1993
2 sentences

2003Provided the State can show that it was defendant’s blood that was used to determine defendant’s BAC, then such BAC test results may be introduced under section 11 — 501.4 if the other criteria for admissibility set forth in that section are met.” (Emphasis added.) People v. Ethridge, 243 Ill.

2003Provided the State can show that it was defendant's blood that was used to determine defendant's BAC, then such BAC test results may be introduced under section 11-501.4 if the other criteria for admissibility set forth in that section are met." Ethridge, 243 Ill.App.3d at 464 , 183 Ill.Dec. 61 , 610 N.E.2d at 1316 .

22003–2003
People v. Pomykala green
ill · 2003
1 sentence

2022Pomykala, 203 Ill. 2d at 203-04 . ¶ 33 The admission of the BAC test result in this case does not create a mandatory presumption.

12022–2022
People v. Epstein green
ill · 2022
1 sentence

2022Id. ¶4 Defendant filed a pretrial motion to exclude her BAC test result of 0.107 obtained from blood drawn pursuant to a search warrant approximately four hours after the traffic stop.

12022–2022
People v. Bates green
illappct · 2018
2 sentences

2021People v. Bates, 2018 IL App (4th) 160255, ¶ 84 . ¶ 29 Here, as the trial court found, the BAC test result was probative of the issue of defendant’s BAC when she was driving.

2021People v. Bates, 2018 IL App (4th) 160255, ¶ 84 . ¶ 29 Here, as the trial court found, the BAC test result was probative of the issue of defendant’s BAC when she was driving.

12021–2021
Tollett v. Henderson green
scotus · 1973
2 sentences

2020Tollett, 411 U.S. at 266-67 . ¶ 40 Before analyzing defendant’s claim under Strickland, we note that defendant’s claim regarding the motion to suppress the BAC test results is relevant to, at most, one of the two offenses to which he pleaded guilty.

2020Tollett, 411 U.S. at 266-67 . ¶ 40 Before analyzing defendant’s claim under Strickland, we note that defendant’s claim regarding the motion to suppress the BAC test results is relevant to, at most, one of the two offenses to which he pleaded guilty.

12020–2020
People v. Lenz green
illappct · 2019
2 sentences

2019At the hearing on the defendant’s motion to exclude the test results, a State toxicologist testified that it was not unusual to perform a BAC test on a -26- 2019 IL App (2d) 180124 blood sample that was 18 or 19 days old.

2019At the hearing on the defendant’s motion to exclude the test results, a State toxicologist testified that it was not unusual to perform a BAC test on a -26- 2019 IL App (2d) 180124 blood sample that was 18 or 19 days old.

12019–2019
Wade v. City of Chicago Heights green
illappct · 1991
2 sentences

2011In fact, in Wade , this court noted: "Although one who is intoxicated can be said to be under the influence of alcohol, the converse is not necessarily true: one may be under the influence of alcohol in varying degrees [citations] without necessarily being considered intoxicated. [Citations.] As previously noted, neither section 11-501 nor section 11-501.2 employs the term `intoxicated.' [Citations.] Nor is the concept of being under the influence anywhere statutorily equated with being intoxicated." Wade, 216 Ill.App.3d at 434 , 159 Ill.Dec. 228 , 575 N.E.2d 1288 . ¶ 116 Defendants argue that

2011In fact, in Wade , this court noted: "Although one who is intoxicated can be said to be under the influence of alcohol, the converse is not necessarily true: one may be under the influence of alcohol in varying degrees [citations] without necessarily being considered intoxicated. [Citations.] As previously noted, neither section 11-501 nor section 11-501.2 employs the term `intoxicated.' [Citations.] Nor is the concept of being under the influence anywhere statutorily equated with being intoxicated." Wade, 216 Ill.App.3d at 434 , 159 Ill.Dec. 228 , 575 N.E.2d 1288 . ¶ 116 Defendants argue that

12011–2011
People v. Morris green
illappct · 2009
2 sentences

2011Morris, 394 Ill.App.3d at 680 , 334 Ill.Dec. 404 , 917 N.E.2d 1 . ¶ 11 Section 11-501.2 of the Illinois Vehicle Code (625 ILCS 5/11-501.2 (West 2006)) governs the admissibility of BAC test results in DUI prosecutions.

2011Morris, 394 Ill.App.3d at 680 , 334 Ill.Dec. 404 , 917 N.E.2d 1 . ¶ 11 Section 11-501.2 of the Illinois Vehicle Code (625 ILCS 5/11-501.2 (West 2006)) governs the admissibility of BAC test results in DUI prosecutions.

12011–2011
People v. Ebert green
illappct · 2010
2 sentences

2011Relying on this court's opinion in People v. Ebert, 401 Ill.App.3d 958 , 341 Ill.Dec. 671 , 931 N.E.2d 279 (2010), the State argues that the BAC test results should be admitted as long as the testing procedures substantially complied with the regulations. ¶ 14 We first address the State's noncompliance with subsection (d), which commands that the tubes used to contain the blood for testing "contain an anticoagulant and preservative." 20 Ill.

2011Relying on this court's opinion in People v. Ebert, 401 Ill.App.3d 958 , 341 Ill.Dec. 671 , 931 N.E.2d 279 (2010), the State argues that the BAC test results should be admitted as long as the testing procedures substantially complied with the regulations. ¶ 14 We first address the State's noncompliance with subsection (d), which commands that the tubes used to contain the blood for testing "contain an anticoagulant and preservative." 20 Ill.

12011–2011
People v. Mueller green
illappct · 1991
2 sentences

1999It is of no effect that the written report was dated December 29, 12 days after the accident. 625 ILCS 5/11- 501.4(a)(3) (West 1996); cf. 625 ILCS 5/11-501.4 (West 1992); People v. Mueller, 221 Ill.

1999It is of no effect that the written report was dated December 29, 12 days after the accident. 625 ILCS 5/11- 501.4(a)(3) (West 1996); cf. 625 ILCS 5/11-501.4 (West 1992); People v. Mueller, 221 Ill.

11999–1999

Statutes the citing opinions construe

IL § 625 ILCS 5/11-501.2 (12) IL § 625 ILCS 5/11-501 (11) IL § 720 ILCS 5/31-1 (5) IL § 625 ILCS 5/11-501.1 (4) IL § 625 ILCS 5/11-401 (3) IL § 720 ILCS 5/4-6 (3) IL § 720 ILCS 5/9-3 (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

OH 95 (1991–2020) PA 86 (1992–2026) ID 46 (1990–2025) TX 37 (1999–2024) NM 36 (1993–2025) MO 27 (1992–2019) IL 20 (1999–2025) WA 19 (1989–2016) CO 19 (1987–2025) HI 19 (1996–2025) OR 18 (1993–2025) CA 17 (1992–2025) AZ 15 (1990–2024) IN 11 (1988–2018) MT 11 (1992–2021) MS 10 (1997–2023) VT 10 (1989–2018) NJ 8 (1990–2015) TN 7 (2009–2025) NY 7 (2013–2026) VA 6 (2004–2024) WI 6 (1997–2021) DE 6 (1988–2024) SC 6 (1997–2023) KS 5 (1993–2020) NH 4 (1985–2021) AL 4 (2011–2023) GA 4 (2015–2023) MI 4 (2006–2025) CT 4 (1992–1996) MN 4 (2014–2018) KY 3 (2007–2021) RI 3 (1998–2021) NC 3 (2017–2019) LA 3 (1995–2024) ND 3 (1993–2015) MD 3 (1995–2007) FL 3 (2014–2017) IA 3 (2017–2017) MA 2 (1993–2020) WY 2 (2014–2020) AR 2 (2020–2020)

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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