results test (Pennsylvania) · Go Syfert
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results test in Pennsylvania

111 Pennsylvania opinions name it 14 courts 1911–2026 17 in the last five years

The cases below were cited by Pennsylvania 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 (41)

CaseFollowedCited
Commonwealth v. Smithgreen
pasuperct · 2019 · cited in 4 Pennsylvania opinions naming this issue, 2020–2023
2 sentences

2023Commonwealth v. Sheets, ___ A.3d ___, 2023 PA Super 154, at *13 (Pa. Super. filed August 10, 2023); Commonwealth v. Smith, 206 A.3d 551, 567 (Pa. Super. 2019); Dempster, 187 A.3d at 272-73 .

2021Commonwealth v. Smith, 206 A.3d 551, 567 (Pa. Super. 2019).

44
Commonwealth v. Trefrygreen
pasuperct · 1977 · cited in 4 Pennsylvania opinions naming this issue, 1978–1988
2 sentences

1988In the earlier case of Commonwealth v. Trefry, 249 Pa.Super. 117 , 375 A.2d 786 (1977), this Court held: “At trial, the results of a test, as indicative of intoxication at a relevant point in time, may be attacked or contradicted by any competent evidence.

1988In the earlier case of Commonwealth v. Trefry, 249 Pa.Super. 117 , 375 A.2d 786 (1977), this Court held: “At trial, the results of a test, as indicative of intoxication at a relevant point in time, may be attacked or contradicted by any competent evidence.

34
Forest Highlands Community Ass'n v. Hammergreen
pasuperct · 2005 · cited in 3 Pennsylvania opinions naming this issue, 2018–2018
2 sentences

2018See Forest Highlands Cmty. -5- J-A09045-18 Ass’n v. Hammer, 879 A.2d 223, 229 (Pa. Super. 2004).

2018See Forest Highlands Cmty. -5- J-A09045-18 Ass’n v. Hammer, 879 A.2d 223, 229 (Pa. Super. 2004).

33
Commonwealth v. Talleygreen
pa · 1974 · cited in 2 Pennsylvania opinions naming this issue, 1979–1980
2 sentences

1980Neither may defendant introduce the results of such a test, Commonwealth v. Brooks, supra, (opinion of O’Brien, J., joined by Pomeroy, J.); see, Commonwealth v. Talley, 456 Pa. 574 , 318 A.2d 922 (1974) (opinion of O’Brien, J.), or evidence that he was willing to take such a test, Commonwealth v. Saunders, supra. Id., 270 Pa.Super. at 11 , 410 A.3d at 871. 4 Eight days after the lower court imposed the sentences, appellant, pursuant to Pa.R.Crim.P., Rule 1410, filed a motion to modify the sentences.

1980Neither may defendant introduce the results of such a test, Commonwealth v. Brooks, supra, (opinion of O’Brien, J., joined by Pomeroy, J.); see, Commonwealth v. Talley, 456 Pa. 574 , 318 A.2d 922 (1974) (opinion of O’Brien, J.), or evidence that he was willing to take such a test, Commonwealth v. Saunders, supra. Id., 270 Pa.Super. at 11 , 410 A.3d at 871. 4 Eight days after the lower court imposed the sentences, appellant, pursuant to Pa.R.Crim.P., Rule 1410, filed a motion to modify the sentences.

22
Com. v. Clary, T.green
pasuperct · 2020 · cited in 1 Pennsylvania opinions naming this issue, 2026–2026
1 sentence

2026See Clary, 226 A.3d at 579 n.7.

11
Commonwealth v. Reid, A., Apltgreen
pa · 2014 · cited in 1 Pennsylvania opinions naming this issue, 2026–2026
1 sentence

2026See Commonwealth v. Reid, 99 A.3d 427, 437 (Pa. 2014).

11
Orange Stones Co. v. City of Reading, Zoning Hearing Boardgreen
pacommwct · 2011 · cited in 1 Pennsylvania opinions naming this issue, 2024–2024
1 sentence

2024Orange Stones Co. v. City of Reading, 32 A.3d 287, 291 (Pa. Cmwlth. 2011); see also Pa.R.A.P. 302(a).

11
Commonwealth v. Currygreen
pa · 2017 · cited in 1 Pennsylvania opinions naming this issue, 2023–2023
1 sentence

2023See Commonwealth v. Baez, 169 A.3d 35, 41 (Pa.Super. 2017) (holding appellant waived claim on appeal regarding why he was entitled to withdraw his guilty plea that was not advanced before trial court); Commonwealth v. Reeves, 907 A.2d 1 (Pa.Super. 2006), appeal denied, 591 Pa. 712 , 919 A.2d 956 (2007) (explaining that appellant is obligated to give trial court notice in Rule 1925(b) statement as to what court should address in its Rule 1925(a) opinion; where specific issue raised on appeal was not presented to court in concise statement such that court had opportunity to address claim in its

11
Com. v. Mulkin, O.green
pasuperct · 2020 · cited in 1 Pennsylvania opinions naming this issue, 2023–2023
1 sentence

2023Pa.R.A.P. 2119(b); see Commonwealth v. Mulkin, 228 A.3d 913, 917 (Pa. Super. 2020) (noting that failure to develop an argument with citation to pertinent authority results in waiver).

11
Com. v. Sheets, R.green
pasuperct · 2023 · cited in 1 Pennsylvania opinions naming this issue, 2023–2023
1 sentence

2023Commonwealth v. Sheets, ___ A.3d ___, 2023 PA Super 154, at *13 (Pa. Super. filed August 10, 2023); Commonwealth v. Smith, 206 A.3d 551, 567 (Pa. Super. 2019); Dempster, 187 A.3d at 272-73 .

11
Commonwealth v. Lincolngreen
pasuperct · 2013 · cited in 1 Pennsylvania opinions naming this issue, 2023–2023
1 sentence

2023See Commonwealth v. Lincoln, 72 A.3d 606, 609-10 (Pa. Super. 2013) (“A defendant wishing to challenge the voluntariness of a guilty plea … must either object during the plea colloquy or file a motion to withdraw the plea within ten days of sentencing.

11
Com. v. Washingtongreen
pasuperct · 2003 · cited in 1 Pennsylvania opinions naming this issue, 2022–2022
1 sentence

2022See Commonwealth v. Washington, 825 A.2d 1264, 1266 (Pa. Super. 2003) (holding that the failure to raise a weight challenge before the trial court results in waiver of the claim on appeal).

11
Commonwealth v. Yohegreen
pa · 2013 · cited in 1 Pennsylvania opinions naming this issue, 2022–2022
1 sentence

2022Commonwealth v. Yohe, 79 A.3d 520, 555 (Pa. 2013).

11
Commonwealth v. Sherwoodgreen
pa · 2009 · cited in 1 Pennsylvania opinions naming this issue, 2021–2021
1 sentence

2021Commonwealth v. Sherwood, 982 A.2d 483, 494 (Pa. 2009); Commonwealth v. Cox, 231 A.3d 1011, 1018 (Pa. Super. 2020).

11
Bednarek v. Velazquezgreen
pasuperct · 2003 · cited in 1 Pennsylvania opinions naming this issue, 2021–2021
1 sentence

2021Instead, Father continued with the hearing and in fact, presented his position to the court first and prior to any presentation by Mr. Bertin. [See Bednarek v. Velasquez], 830 A.2d 1267, 1270 (Pa.Super. 2003) (holding that acquiescence to a procedure employed by the trial court results in waiver of any challenge to that procedure on appeal).

11
Commonwealth v. Robinsongreen
pa · 1995 · cited in 1 Pennsylvania opinions naming this issue, 2021–2021
2 sentences

2021See, e.g., Commonwealth v. Robinson, 670 A.2d 616, 620 (Pa. 1995) (collecting cases holding that failure to raise issue before the trial court results in waiver); Pa.R.A.P. 302.

2021Id.

11
Com. v. Cox, V., Jr.green
pasuperct · 2020 · cited in 1 Pennsylvania opinions naming this issue, 2021–2021
1 sentence

2021Commonwealth v. Sherwood, 982 A.2d 483, 494 (Pa. 2009); Commonwealth v. Cox, 231 A.3d 1011, 1018 (Pa. Super. 2020).

11
Commonwealth v. Mourygreen
pasuperct · 2010 · cited in 1 Pennsylvania opinions naming this issue, 2020–2020
1 sentence

2020Commonwealth v. Moury, 992 A.2d 162, 170 (Pa. Super. 2010).

11
Commonwealth v. Napoldgreen
pasuperct · 2017 · cited in 1 Pennsylvania opinions naming this issue, 2020–2020
1 sentence

2020See Commonwealth v. Napold, 170 A.3d 1165, 1168 (Pa. Super. -8- J-A30034-19 error in the denial of Appellant’s suppression motion on this ground.

11
Burnhauser v. Bumbergergreen
pasuperct · 2000 · cited in 1 Pennsylvania opinions naming this issue, 2019–2019
11
Dollar Bank v. Swartzgreen
pa · 1995 · cited in 1 Pennsylvania opinions naming this issue, 2019–2019
2 sentences

2019Pa. R.A.P. 302(a); Dollar Bank v. Swartz, 540 Pa. 369 , 657 A.2d 1242, 1245 (1995) (citations omitted) (“It is - 11 - J-S18042-19 a fundamental principle of appellate review that we will not reverse a judgment or decree on a theory that was not presented to the trial court.”).

2019Pa. R.A.P. 302(a); Dollar Bank v. Swartz, 540 Pa. 369 , 657 A.2d 1242, 1245 (1995) (citations omitted) (“It is - 11 - J-S18042-19 a fundamental principle of appellate review that we will not reverse a judgment or decree on a theory that was not presented to the trial court.”).

11
Commonwealth v. Lopezgreen
pasuperct · 2012 · cited in 1 Pennsylvania opinions naming this issue, 2019–2019
11
Commonwealth v. Kinneygreen
pasuperct · 2017 · cited in 1 Pennsylvania opinions naming this issue, 2019–2019
11
Commonwealth v. Petrollgreen
pa · 1999 · cited in 1 Pennsylvania opinions naming this issue, 2018–2018
11
Commonwealth v. Stringergreen
pasuperct · 1996 · cited in 1 Pennsylvania opinions naming this issue, 2018–2018
11
Commonwealth v. Bryantgreen
pasuperct · 2012 · cited in 1 Pennsylvania opinions naming this issue, 2018–2018
11
Commonwealth v. Bartongreen
pasuperct · 1997 · cited in 1 Pennsylvania opinions naming this issue, 2017–2017
11
Commonwealth v. Son Truonggreen
pasuperct · 2012 · cited in 1 Pennsylvania opinions naming this issue, 2017–2017
11
E.D. v. M.P.green
pasuperct · 2011 · cited in 1 Pennsylvania opinions naming this issue, 2016–2016
11
Commonwealth v. Birdsonggreen
pa · 2011 · cited in 1 Pennsylvania opinions naming this issue, 2015–2015
11
Commonwealth v. Smithgreen
pa · 2013 · cited in 1 Pennsylvania opinions naming this issue, 2014–2014
11
In re Estate of Boylegreen
pasuperct · 2013 · cited in 1 Pennsylvania opinions naming this issue, 2014–2014
11
Sonnier v. Craingreen
ca5 · 2011 · cited in 1 Pennsylvania opinions naming this issue, 2013–2013
11
Commonwealth v. Caingreen
pasuperct · 2006 · cited in 1 Pennsylvania opinions naming this issue, 2012–2012
11
Ellison v. Lopezgreen
pasuperct · 2008 · cited in 1 Pennsylvania opinions naming this issue, 2009–2009
11
Commonwealth v. Natividadgreen
pa · 2007 · cited in 1 Pennsylvania opinions naming this issue, 2008–2008
11
COM., DEPT. OF TRANS. v. Scottgreen
pa · 1996 · cited in 1 Pennsylvania opinions naming this issue, 1998–1998
11
Jones v. Trojakgreen
pasuperct · 1991 · cited in 1 Pennsylvania opinions naming this issue, 1994–1994
11
Books v. Commonwealthgreen
pacommwct · 1987 · cited in 1 Pennsylvania opinions naming this issue, 1994–1994
11
Commonwealth v. Haynosgreen
pa · 1987 · cited in 1 Pennsylvania opinions naming this issue, 1993–1993
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (39)

CaseCitedYears
Commonwealth v. Miles green
pacommwct · 1973
2 sentences

1974It is a factual determination not a legal determination.” ( 8 Pa. Commonwealth Ct. at 551 , 304 A. 2d at 708 .) See also Bureau of Traffic Safety v. Drugotch, 9 Pa. Commonwealth Ct. 460 , 308 A. 2d 183 (1973).

1974It is a factual determination not a legal determination.” ( 8 Pa. Commonwealth Ct. at 551 , 304 A. 2d at 708 .) See also Bureau of Traffic Safety v. Drugotch, 9 Pa. Commonwealth Ct. 460 , 308 A. 2d 183 (1973).

41973–1974
Miranda v. Arizona green
scotus · 1966
2 sentences

2017The suppression court denied Brophy- Desante’s Motion to suppress. 3 A NIK test (Narcotic Identification Kit) is a presumptive field test used to identify drugs and controlled substances. 4 A sample of the substance was also sent to the state police lab for testing, but the results of that test were not available at the time of the pretrial hearing. 5 Miranda v. Arizona, 384 U.S. 436 (1966). -3- J-A15031-17 Following a jury trial, Brophy-Desante was convicted of one count of possession of a controlled substance.

1970This officer then proceeded, for the first time, to inform Bennett of his rights pursuant to the formula mandated by Miranda, v. Arizona, 384 U.S. 436 , 86 S. Ct. 1602 (1966).

21970–2017
Commonwealth v. Saunders green
pa · 1956
2 sentences

1974The appellate courts in Pennsylvania have repeatedly held that the results of a polygraph examination are not admissible evidence for any purpose: Commonwealth v. Saunders, 386 Pa. 149 , 125 A. 2d 442 (1956); Commonwealth v. McKinley, 181 Pa. Superior Ct. 610 , 123 A. 2d 735 (1956); Commonwealth ex rel.

1974The appellate courts in Pennsylvania have repeatedly held that the results of a polygraph examination are not admissible evidence for any purpose: Commonwealth v. Saunders, 386 Pa. 149 , 125 A. 2d 442 (1956); Commonwealth v. McKinley, 181 Pa. Superior Ct. 610 , 123 A. 2d 735 (1956); Commonwealth ex rel.

21971–1974
Irvin v. Bleakley neutral
pa · 1871
2 sentences

1933In the case of Irvin v. Bleakley, 67 Pa. 24, 28 , the court said: “The vendee must tender the unpaid purchase money, as a general thing, whether he wishes to rescind or enforce the agreement......There were two other judgments against the defendant and others, amounting to some six or seven thousand dollars, which the purchase money in the hands of the plaintiffs would nearly three times over have satisfied.

1911The vendee must tender the unpaid purchase money, as a general thing, whether he wishes to rescind or to enforce the agreement; this results from the principle that a party himself in default, has no right to insist on rescission while in default: Irvin v. Bleakley, 67 Pa. 24 .

21911–1933
Bs v. Tm green
pasuperct · 2001
1 sentence

2024B.S., 782 A.2d at 1031-32 . [J-61-2023] - 20 and her husband “voluntarily gave up the benefit of the presumption for approximately one year after which they claimed the benefits of its existence,” the court found that any damage to the marriage was “water under the bridge,” as the couple had reconciled with complete awareness of the events that occurred.

12024–2024
Commonwealth v. Dempster green
pasuperct · 2018
1 sentence

2023Commonwealth v. Sheets, ___ A.3d ___, 2023 PA Super 154, at *13 (Pa. Super. filed August 10, 2023); Commonwealth v. Smith, 206 A.3d 551, 567 (Pa. Super. 2019); Dempster, 187 A.3d at 272-73 .

12023–2023
Commonwealth v. Reeves green
pasuperct · 2006
1 sentence

2023See Commonwealth v. Baez, 169 A.3d 35, 41 (Pa.Super. 2017) (holding appellant waived claim on appeal regarding why he was entitled to withdraw his guilty plea that was not advanced before trial court); Commonwealth v. Reeves, 907 A.2d 1 (Pa.Super. 2006), appeal denied, 591 Pa. 712 , 919 A.2d 956 (2007) (explaining that appellant is obligated to give trial court notice in Rule 1925(b) statement as to what court should address in its Rule 1925(a) opinion; where specific issue raised on appeal was not presented to court in concise statement such that court had opportunity to address claim in its

12023–2023
Commonwealth, Aplt. v. Myers, D. green
pa · 2017
1 sentence

2022The police officer requested the results of that test under the authority of a different statute[, Section 3755].” Myers, 164 A.3d at 670 n. 14. [J-41-2022] - 17 Because the record does not establish that Section 3755 applied under these circumstances, the subsequent analysis of the statute’s constitutionality should not be addressed.

12022–2022
Boseman v. Commonwealth, Department of Transportation, Bureau of Driver Licensing green
pacommwct · 2017
2 sentences

2021In holding the test results were admissible, the trial court stated that “[t]he evidence was admitted specifically for the purpose of establishing that [Licensee] was driving in an intoxicated state and not to show any culpability for [DUI].” (Trial ct. op. at 7.) Lastly, the trial court addressed Licensee’s claim that the license suspension was “illegal as an unconstitutional civil penalty imposed on an individual’s exercise of the Fourth Amendment right to refuse consent to a warrantless search.” (Trial ct. op., at 7.) Relying on Boseman v. Department of Transportation, Bureau of Licensing,

2021In holding the test results were admissible, the trial court stated that “[t]he evidence was admitted specifically for the purpose of establishing that [Licensee] was driving in an intoxicated state and not to show any culpability for [DUI].” (Trial ct. op. at 7.) Lastly, the trial court addressed Licensee’s claim that the license suspension was “illegal as an unconstitutional civil penalty imposed on an individual’s exercise of the Fourth Amendment right to refuse consent to a warrantless search.” (Trial ct. op., at 7.) Relying on Boseman v. Department of Transportation, Bureau of Licensing,

12021–2021
Commonwealth v. Janda green
pasuperct · 2011
1 sentence

2019Janda, 14 A.3d at 164 .

12019–2019
Gephart v. Gephart green
pasuperct · 2000
12019–2019
Commonwealth v. Chmiel green
pa · 2005
12019–2019
Commonwealth v. Apollo green
pasuperct · 1992
12018–2018
Commonwealth v. Speights green
pa · 1986
12017–2017
Commonwealth v. Mallory green
pa · 2008
12015–2015
Walls v. Scheckler green
pasuperct · 1997
12015–2015
Commonwealth v. Wilson green
pasuperct · 2003
12014–2014
Brady v. Maryland green
scotus · 1963
12013–2013
Commonwealth v. Smith green
pa · 1977
12013–2013
Commonwealth v. Yohe green
pasuperct · 2012
12013–2013
Sonnier v. Crain green
ca5 · 2011
12013–2013
Com. v. Cartwright green
pa · 2007
12012–2012
Commonwealth v. Sneeringer green
pasuperct · 1995
12000–2000
Commonwealth v. Steadley green
pasuperct · 2000
12000–2000
Merriweather v. Philadelphia Newspapers, Inc. green
pasuperct · 1996
11999–1999
Commonwealth v. Hipp green
pa · 1988
11997–1997
Commonwealth v. Eisenhart green
pa · 1992
11994–1994
Commonwealth v. Orlando neutral
pacommwct · 1988
11994–1994
Wong Sun v. United States green
scotus · 1963
11994–1994
Commonwealth v. MacKie green
pa · 1974
11994–1994
In Re Apepal From Susupension of Operator's License of Budd green
pacommwct · 1982
11994–1994
Commonwealth v. Mabrey green
pasuperct · 1991
11994–1994
Martin v. Lancaster Battery Co., Inc. green
pa · 1992
11993–1993
Commonwealth v. Modaffare green
pa · 1992
11993–1993
Commonwealth v. Gonzalez green
pa · 1988
11992–1992
Commonwealth v. Tarbert green
pa · 1987
11992–1992
Commonwealth v. Hadfield green
pasuperct · 1985
11991–1991
Commonwealth v. Bennett green
pa · 1983
11991–1991
Bartle v. Bartle green
pasuperct · 1982
11991–1991

Statutes the citing opinions construe

PA § 75 Pa. Cons. Stat. § 1547 (21) PA § 75 Pa. Cons. Stat. § 3731 (12) PA § 75 Pa. Cons. Stat. § 3802 (8) PA § 18 Pa. Cons. Stat. § 2705 (4) PA § 75 Pa. Cons. Stat. § 3755 (4)

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

TX 163 (1929–2025) OH 129 (1963–2026) NY 115 (1855–2025) PA 111 (1911–2026) IL 105 (1919–2026) CA 91 (1907–2026) GA 81 (1912–2024) NC 76 (1919–2026) VA 62 (1851–2025) IN 59 (1885–2026) TN 59 (1957–2025) MI 51 (1959–2025) CT 46 (1874–2025) OR 36 (1969–2026) AL 36 (1916–2008) FL 32 (1953–2025) MO 31 (1961–2024) IA 30 (1908–2023) NM 29 (1961–2023) NJ 29 (1902–2019) MS 28 (1955–2016) MA 27 (1924–2024) CO 26 (1951–2021) KS 25 (1907–2020) WI 25 (1958–2025) MD 24 (1958–2019) WA 24 (1915–2023) ND 23 (1972–2025) LA 22 (1975–2016) AZ 18 (1931–2024) DE 17 (1973–2021) AR 17 (1930–2025) AK 16 (1979–2016) MN 16 (1943–2016) KY 16 (1957–2025) ID 15 (1958–2026) DC 15 (1972–2025) OK 15 (1956–1997) NE 13 (1942–2021) UT 13 (1984–2026) SD 10 (1917–2012) HI 9 (1987–2010) WY 8 (1970–2011) RI 8 (1959–2007) WV 8 (1981–2023) NH 7 (1969–2025) VT 7 (1931–2018) NV 6 (1988–2022) ME 6 (1962–2020) MT 5 (1976–2009) SC 5 (1975–2026)

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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