field test in Washington

14 Washington opinions name it 2 courts 1946–2024 1 in the last five years

The cases below were cited by Washington 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 (2)

Case	Followed	Cited
United States v. Raul Dominguezgreen ca7 · 1993 · cited in 2 Washington opinions naming this issue, 2006–2006 2 sentences 2006As a matter of fact, we specifically state that circumstantial evidence may be sufficient (citing Delmarter, 124 Wash.App. at 163-64 , 101 P.3d 111 , (even without a laboratory test, an independent field test and confession support a conviction for possession of a controlled substance); Hernandez, 85 Wash.App. at 675 , 935 P.2d 623 (circumstantial evidence and lay testimony may be sufficient to establish the identity of a controlled substance); and Dominguez, 992 F.2d at 681 (circumstantial evidence establishing a controlled substance beyond a reasonable doubt may include lay experience based 2006App. at 675 (circumstantial evidence and lay testimony may be sufficient to establish the identity of a controlled substance); and Dominguez, 992 F.2d at 681 (circumstantial evidence establishing a controlled substance beyond a reasonable doubt may include lay experience based on familiarity through prior use, trading, or law enforcement)). ¶22 But the problem here is the paucity of information supporting the officer’s identification of the white, rock-like items.	2	2
State v. Hernandezgreen washctapp · 1997 · cited in 2 Washington opinions naming this issue, 2006–2006 2 sentences 2006As a matter of fact, we specifically state that circumstantial evidence may be sufficient (citing Delmarter, 124 Wash.App. at 163-64 , 101 P.3d 111 , (even without a laboratory test, an independent field test and confession support a conviction for possession of a controlled substance); Hernandez, 85 Wash.App. at 675 , 935 P.2d 623 (circumstantial evidence and lay testimony may be sufficient to establish the identity of a controlled substance); and Dominguez, 992 F.2d at 681 (circumstantial evidence establishing a controlled substance beyond a reasonable doubt may include lay experience based 2006App. at 163-64 (even without a laboratory test, an independent field test and confession support a conviction for possession of a controlled substance); Hernandez, 85 Wn.	1	2

Distinguished, questioned or overruled (0)

Case	Negative	Cited
No negative-treatment citations attached to this issue in Washington. Read the followed side critically anyway.

Also cited on this issue (20)

Case	Cited	Years
State v. Hundley green wash · 1995 2 sentences 2006Hundley, 126 Wash.2d at 420-21 , 895 P.2d 403 . 2006Hundley, 126 Wn.2d at 420-21 .	2	2006–2006
State v. Roche green washctapp · 2002 2 sentences 2006Roche, 114 Wn. 2006Roche, 114 Wn.	2	2006–2006
In re the Personal Restraint of Delmarter green washctapp · 2004 2 sentences 2006As a matter of fact, we specifically state that circumstantial evidence may be sufficient (citing Delmarter, 124 Wash.App. at 163-64 , 101 P.3d 111 , (even without a laboratory test, an independent field test and confession support a conviction for possession of a controlled substance); Hernandez, 85 Wash.App. at 675 , 935 P.2d 623 (circumstantial evidence and lay testimony may be sufficient to establish the identity of a controlled substance); and Dominguez, 992 F.2d at 681 (circumstantial evidence establishing a controlled substance beyond a reasonable doubt may include lay experience based 2006Delmarter, 124 Wn.	2	2006–2006
In re the Personal Restraint of Brennan neutral washctapp · 2003 2 sentences 2004This court found three significant differences that distinguished Roche: (1) Brennan pleaded guilty whereas Roche and Sweeney went to trial; (2) independent evidence, including a field test and Brennan’s confession, established that the substance taken from Brennan’s person was methamphetamine, whereas Roche did not admit that the substances found in his home were methamphetamines, despite a positive field test; and (3) there was no temporal connection between Hoover’s misconduct in 1998 and his test of the substance found on Brennan in 1996, whereas there was compelling evidence that Hoover w 2004This court found three significant differences that distinguished Roche: (1) Brennan pleaded guilty whereas Roche and Sweeney went to trial; (2) independent evidence including a field test and Brennan's confession established that the substance taken from Brennan's person was methamphetamine, whereas Roche did not admit that the substances found in his home were methamphetamines, despite a positive field test; and (3) there was no temporal connection between Hoover's misconduct in 1998 and his test of the substance found on Brennan in 1996, whereas there was compelling evidence that Hoover was	2	2004–2004
Washington Freightliner, Inc. v. Shantytown Pier, Inc. green md · 1998 2 sentences 2001Wash. Freightliner, 351 Md. at 631-37 , 719 A.2d 541 . 2001Wash. Freightliner, 719 A.2d at 548-51 .	2	2001–2001
Cipollone v. Liggett Group, Inc. green scotus · 1992 2 sentences 1996Cipollone, 505 U.S. at 2617 . 1996Cipollone, 505 U.S. at 515-16 , 112 S.Ct. at 2617 .	2	1996–1996
State v. Colquitt green washctapp · 2006 1 sentence 2024Id. at 792 .	1	2024–2024
State v. Colquitt green washctapp · 2006 1 sentence 2014App. 789 , 137 P.3d 892 (2006), Mr. Amezola contends that the field test conducted by the officer was not sufficient evidence to establish the substance was methamphetamine, absent other supporting evidence such as a laboratory report.	1	2014–2014
State v. Hutton green washctapp · 1972 2 sentences 2006State v. Hutton, 7 Wash.App. 726, 728 , 502 P.2d 1037 (1972) (citing State v. Carter, 5 Wash.App. 802 , 490 P.2d 1346 (1971)). [14] The majority cites Hundley, in which the field test and all but one of the laboratory tests failed to detect the presence of marijuana, heroin, and cocaine. 2006State v. Hutton, 7 Wash.App. 726, 728 , 502 P.2d 1037 (1972) (citing State v. Carter, 5 Wash.App. 802 , 490 P.2d 1346 (1971)). [14] The majority cites Hundley, in which the field test and all but one of the laboratory tests failed to detect the presence of marijuana, heroin, and cocaine.	1	2006–2006
State v. Hernandez green washctapp · 1997 1 sentence 2006As a matter of fact, we specifically state that circumstantial evidence may be sufficient (citing Delmarter, 124 Wash.App. at 163-64 , 101 P.3d 111 , (even without a laboratory test, an independent field test and confession support a conviction for possession of a controlled substance); Hernandez, 85 Wash.App. at 675 , 935 P.2d 623 (circumstantial evidence and lay testimony may be sufficient to establish the identity of a controlled substance); and Dominguez, 992 F.2d at 681 (circumstantial evidence establishing a controlled substance beyond a reasonable doubt may include lay experience based	1	2006–2006
State v. Carter green washctapp · 1971 2 sentences 2006State v. Hutton, 7 Wash.App. 726, 728 , 502 P.2d 1037 (1972) (citing State v. Carter, 5 Wash.App. 802 , 490 P.2d 1346 (1971)). [14] The majority cites Hundley, in which the field test and all but one of the laboratory tests failed to detect the presence of marijuana, heroin, and cocaine. 2006State v. Hutton, 7 Wash.App. 726, 728 , 502 P.2d 1037 (1972) (citing State v. Carter, 5 Wash.App. 802 , 490 P.2d 1346 (1971)). [14] The majority cites Hundley, in which the field test and all but one of the laboratory tests failed to detect the presence of marijuana, heroin, and cocaine.	1	2006–2006
State v. Roche green washctapp · 2002 2 sentences 2006Roche, 114 Wash.App. at 431-32 , 59 P.3d 682 . 2006Roche, 114 Wash.App. at 437-38 , 59 P.3d 682 .	1	2006–2006
In Re Delmarter green washctapp · 2004 2 sentences 2006Delmarter, 124 Wash.App. at 163-64 , 101 P.3d 111 . 2006As a matter of fact, we specifically state that circumstantial evidence may be sufficient (citing Delmarter, 124 Wash.App. at 163-64 , 101 P.3d 111 , (even without a laboratory test, an independent field test and confession support a conviction for possession of a controlled substance); Hernandez, 85 Wash.App. at 675 , 935 P.2d 623 (circumstantial evidence and lay testimony may be sufficient to establish the identity of a controlled substance); and Dominguez, 992 F.2d at 681 (circumstantial evidence establishing a controlled substance beyond a reasonable doubt may include lay experience based	1	2006–2006
In Re Brennan green washctapp · 2003 1 sentence 2004This court found three significant differences that distinguished Roche: (1) Brennan pleaded guilty whereas Roche and Sweeney went to trial; (2) independent evidence including a field test and Brennan's confession established that the substance taken from Brennan's person was methamphetamine, whereas Roche did not admit that the substances found in his home were methamphetamines, despite a positive field test; and (3) there was no temporal connection between Hoover's misconduct in 1998 and his test of the substance found on Brennan in 1996, whereas there was compelling evidence that Hoover was	1	2004–2004
State v. Kinzy green wash · 2000 2 sentences 2004Id. at 378 . 2004Id. at 379 .	1	2004–2004
State v. Kinzy green wash · 2000 2 sentences 2004Id. at 378, 5 P.3d 668 . 2004Id. at 379, 5 P.3d 668 .	1	2004–2004
State v. Smith green wash · 1918 2 sentences 1976State v. Smythe, 148 Wash. 65 , 268 P. 133 (1928); State v. Smith, 103 Wash. 267 , 174 P. 9 (1918); State v. Schuman, 89 Wash. 9 , 153 P. 1084 (1915); Annot., 20 A.L.R.2d 687 (1968). 1976State v. Smythe, 148 Wash. 65 , 268 P. 133 (1928); State v. Smith, 103 Wash. 267 , 174 P. 9 (1918); State v. Schuman, 89 Wash. 9 , 153 P. 1084 (1915); Annot., 20 A.L.R.2d 687 (1968).	1	1976–1976
State v. Smythe green wash · 1928 2 sentences 1976State v. Smythe, 148 Wash. 65 , 268 P. 133 (1928); State v. Smith, 103 Wash. 267 , 174 P. 9 (1918); State v. Schuman, 89 Wash. 9 , 153 P. 1084 (1915); Annot., 20 A.L.R.2d 687 (1968). 1976State v. Smythe, 148 Wash. 65 , 268 P. 133 (1928); State v. Smith, 103 Wash. 267 , 174 P. 9 (1918); State v. Schuman, 89 Wash. 9 , 153 P. 1084 (1915); Annot., 20 A.L.R.2d 687 (1968).	1	1976–1976
State v. Schuman green wash · 1915 2 sentences 1976State v. Smythe, 148 Wash. 65 , 268 P. 133 (1928); State v. Smith, 103 Wash. 267 , 174 P. 9 (1918); State v. Schuman, 89 Wash. 9 , 153 P. 1084 (1915); Annot., 20 A.L.R.2d 687 (1968). 1976State v. Smythe, 148 Wash. 65 , 268 P. 133 (1928); State v. Smith, 103 Wash. 267 , 174 P. 9 (1918); State v. Schuman, 89 Wash. 9 , 153 P. 1084 (1915); Annot., 20 A.L.R.2d 687 (1968).	1	1976–1976
Northwest Cities Gas Co. v. Western Fuel Co. green wash · 1942 1 sentence 1946We revert to the case of Northwest Cities Gas Co. v. Western Fuel Co., 13 Wn. (2d) 75, 123 P. (2d) 771 , and quote *706 therefrom certain fundamental propositions, omitting, however, the supporting citations.	1	1946–1946

Statutes the citing opinions construe

WA § Wash. Rev. Code § 69.50.401 (5)

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

NJ 124 (1918–2026) CT 93 (1896–2022) IL 52 (1942–2025) NY 44 (1902–2026) TX 40 (1977–2026) CA 30 (1903–2020) PA 23 (1924–2026) MA 21 (1911–2025) IN 20 (1916–2025) IA 18 (1899–2025) FL 17 (2000–2017) NM 17 (1978–2025) DC 17 (1955–2022) GA 16 (1985–2024) WA 14 (1946–2024) WY 13 (1922–2018) KS 12 (1889–2004) MD 12 (1957–2007) MO 11 (1887–2025) AL 10 (1926–2017) NC 10 (1918–2018) OR 10 (1928–2025) OK 9 (1931–2004) MI 8 (1907–2022) OH 8 (1950–2021) MN 7 (1938–2024) ND 7 (1973–2021) TN 7 (1979–2026) UT 7 (1906–2025) LA 6 (1977–2014) WI 6 (1978–2026) VA 6 (1939–2022) KY 5 (1938–2026) AZ 5 (1982–2023) DE 5 (1940–2021) MS 5 (1970–2025) ID 4 (1983–2018) ME 3 (1879–1983) CO 3 (1981–2026) SC 3 (1955–2021) MT 3 (1909–2020) WV 2 (1978–2006) RI 2 (1983–1984) GU 2 (1978–2022) VT 2 (2009–2015) NV 2 (2015–2015)

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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