alcohol concentration test (Idaho) · Go Syfert
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alcohol concentration test in Idaho

13 Idaho opinions name it 1 courts 1991–2021 1 in the last five years

The cases below were cited by Idaho 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 (17)

CaseFollowedCited
South Dakota v. Nevillegreen
scotus · 1983 · cited in 1 Idaho opinions naming this issue, 2015–2015
2 sentences

2015See Missouri v. McNeely, — U.S. —, —, 133 S.Ct. 1552, 1566-67 , 185 L.Ed.2d 696, 712-14 (2013) (discussing statutory implied consent schemes that impose administrative penalties for refusal of an alcohol concentration test and that allow admission of a defendant’s refusal into evidence); South Dakota v. Neville, 459 U.S. 553, 554 , 103 S.Ct. 916, 917-18 , 74 L.Ed.2d 748, 753 (1983) (holding that implied consent schemes that allow the State to admit a refusal to submit to testing into evidence do not violate the Fifth Amendment); State v. Declerck, 49 Kan.App.2d 908 , 317 P.3d 794, 803 (2014) (

2015See Missouri v. McNeely, — U.S. —, —, 133 S.Ct. 1552, 1566-67 , 185 L.Ed.2d 696, 712-14 (2013) (discussing statutory implied consent schemes that impose administrative penalties for refusal of an alcohol concentration test and that allow admission of a defendant’s refusal into evidence); South Dakota v. Neville, 459 U.S. 553, 554 , 103 S.Ct. 916, 917-18 , 74 L.Ed.2d 748, 753 (1983) (holding that implied consent schemes that allow the State to admit a refusal to submit to testing into evidence do not violate the Fifth Amendment); State v. Declerck, 49 Kan.App.2d 908 , 317 P.3d 794, 803 (2014) (

11
State of Arizona v. Hon. butler/tyler B.green
ariz · 2013 · cited in 1 Idaho opinions naming this issue, 2015–2015
1 sentence

2015Like Idaho, many states have adopted some version of an implied consent statute that imposes penalties for refusal to submit to alcohol concentration testing at the reasonable request of an officer, but my research has revealed no other jurisdiction where, at least after the United States Supreme Court’s decision in McNeely, ___ U.S. ___, 133 S. Ct. 1552 (2013), the fictitious implied consent was held to satisfy the Fourth Amendment for purposes of a blood draw. 1 The 1 See, e.g., State v. Butler, 302 P.3d 609, 613 (Ariz. 2013); People v. Schaufele, 325 P.3d 1060, 1065-66 (Colo. 2014); Flonnor

11
People v. Schaufelegreen
colo · 2014 · cited in 1 Idaho opinions naming this issue, 2015–2015
1 sentence

2015Like Idaho, many states have adopted some version of an implied consent statute that imposes penalties for refusal to submit to alcohol concentration testing at the reasonable request of an officer, but my research has revealed no other jurisdiction where, at least after the United States Supreme Court’s decision in McNeely, ___ U.S. ___, 133 S. Ct. 1552 (2013), the fictitious implied consent was held to satisfy the Fourth Amendment for purposes of a blood draw. 1 The 1 See, e.g., State v. Butler, 302 P.3d 609, 613 (Ariz. 2013); People v. Schaufele, 325 P.3d 1060, 1065-66 (Colo. 2014); Flonnor

11
State v. Padleygreen
wisctapp · 2014 · cited in 1 Idaho opinions naming this issue, 2015–2015
2 sentences

2015See Missouri v. McNeely, — U.S. —, —, 133 S.Ct. 1552, 1566-67 , 185 L.Ed.2d 696, 712-14 (2013) (discussing statutory implied consent schemes that impose administrative penalties for refusal of an alcohol concentration test and that allow admission of a defendant’s refusal into evidence); South Dakota v. Neville, 459 U.S. 553, 554 , 103 S.Ct. 916, 917-18 , 74 L.Ed.2d 748, 753 (1983) (holding that implied consent schemes that allow the State to admit a refusal to submit to testing into evidence do not violate the Fifth Amendment); State v. Declerck, 49 Kan.App.2d 908 , 317 P.3d 794, 803 (2014) (

2015See Missouri v. McNeely, — U.S. —, —, 133 S.Ct. 1552, 1566-67 , 185 L.Ed.2d 696, 712-14 (2013) (discussing statutory implied consent schemes that impose administrative penalties for refusal of an alcohol concentration test and that allow admission of a defendant’s refusal into evidence); South Dakota v. Neville, 459 U.S. 553, 554 , 103 S.Ct. 916, 917-18 , 74 L.Ed.2d 748, 753 (1983) (holding that implied consent schemes that allow the State to admit a refusal to submit to testing into evidence do not violate the Fifth Amendment); State v. Declerck, 49 Kan.App.2d 908 , 317 P.3d 794, 803 (2014) (

11
People v. Gaedegreen
illappct · 2014 · cited in 1 Idaho opinions naming this issue, 2015–2015
1 sentence

2015Like Idaho, many states have adopted some version of an implied consent statute that imposes penalties for refusal to submit to alcohol concentration testing at the reasonable request of an officer, but my research has revealed no other jurisdiction where, at least after the United States Supreme Court’s decision in McNeely, ___ U.S. ___, 133 S. Ct. 1552 (2013), the fictitious implied consent was held to satisfy the Fourth Amendment for purposes of a blood draw. 1 The 1 See, e.g., State v. Butler, 302 P.3d 609, 613 (Ariz. 2013); People v. Schaufele, 325 P.3d 1060, 1065-66 (Colo. 2014); Flonnor

11
State v. Edmondsongreen
idahoctapp · 1994 · cited in 1 Idaho opinions naming this issue, 2015–2015
2 sentences

2015Edmondson, 125 Idaho at 135 , 867 P.2d at 1009 (citation omitted).

2015Edmondson, 125 Idaho at 135 , 867 P.2d at 1009 (citation omitted).

11
Missouri v. McNeelygreen
scotus · 2013 · cited in 1 Idaho opinions naming this issue, 2015–2015
2 sentences

2015See Missouri v. McNeely, — U.S. —, —, 133 S.Ct. 1552, 1566-67 , 185 L.Ed.2d 696, 712-14 (2013) (discussing statutory implied consent schemes that impose administrative penalties for refusal of an alcohol concentration test and that allow admission of a defendant’s refusal into evidence); South Dakota v. Neville, 459 U.S. 553, 554 , 103 S.Ct. 916, 917-18 , 74 L.Ed.2d 748, 753 (1983) (holding that implied consent schemes that allow the State to admit a refusal to submit to testing into evidence do not violate the Fifth Amendment); State v. Declerck, 49 Kan.App.2d 908 , 317 P.3d 794, 803 (2014) (

2015See Missouri v. McNeely, — U.S. —, —, 133 S.Ct. 1552, 1566-67 , 185 L.Ed.2d 696, 712-14 (2013) (discussing statutory implied consent schemes that impose administrative penalties for refusal of an alcohol concentration test and that allow admission of a defendant’s refusal into evidence); South Dakota v. Neville, 459 U.S. 553, 554 , 103 S.Ct. 916, 917-18 , 74 L.Ed.2d 748, 753 (1983) (holding that implied consent schemes that allow the State to admit a refusal to submit to testing into evidence do not violate the Fifth Amendment); State v. Declerck, 49 Kan.App.2d 908 , 317 P.3d 794, 803 (2014) (

11
State v. Declerckgreen
kanctapp · 2014 · cited in 1 Idaho opinions naming this issue, 2015–2015
2 sentences

2015See Missouri v. McNeely, — U.S. —, —, 133 S.Ct. 1552, 1566-67 , 185 L.Ed.2d 696, 712-14 (2013) (discussing statutory implied consent schemes that impose administrative penalties for refusal of an alcohol concentration test and that allow admission of a defendant’s refusal into evidence); South Dakota v. Neville, 459 U.S. 553, 554 , 103 S.Ct. 916, 917-18 , 74 L.Ed.2d 748, 753 (1983) (holding that implied consent schemes that allow the State to admit a refusal to submit to testing into evidence do not violate the Fifth Amendment); State v. Declerck, 49 Kan.App.2d 908 , 317 P.3d 794, 803 (2014) (

2015See Missouri v. McNeely, — U.S. —, —, 133 S.Ct. 1552, 1566-67 , 185 L.Ed.2d 696, 712-14 (2013) (discussing statutory implied consent schemes that impose administrative penalties for refusal of an alcohol concentration test and that allow admission of a defendant’s refusal into evidence); South Dakota v. Neville, 459 U.S. 553, 554 , 103 S.Ct. 916, 917-18 , 74 L.Ed.2d 748, 753 (1983) (holding that implied consent schemes that allow the State to admit a refusal to submit to testing into evidence do not violate the Fifth Amendment); State v. Declerck, 49 Kan.App.2d 908 , 317 P.3d 794, 803 (2014) (

11
Flonnory v. Stategreen
del · 2015 · cited in 1 Idaho opinions naming this issue, 2015–2015
1 sentence

2015Like Idaho, many states have adopted some version of an implied consent statute that imposes penalties for refusal to submit to alcohol concentration testing at the reasonable request of an officer, but my research has revealed no other jurisdiction where, at least after the United States Supreme Court’s decision in McNeely, ___ U.S. ___, 133 S. Ct. 1552 (2013), the fictitious implied consent was held to satisfy the Fourth Amendment for purposes of a blood draw. 1 The 1 See, e.g., State v. Butler, 302 P.3d 609, 613 (Ariz. 2013); People v. Schaufele, 325 P.3d 1060, 1065-66 (Colo. 2014); Flonnor

11
State v. Sutliffgreen
idaho · 1976 · cited in 1 Idaho opinions naming this issue, 2013–2013
2 sentences

2013Although Idaho Code § 18-8004 does not impose a timeframe in which the alcohol concentration test must be taken, the Supreme Court has noted that any " 'lapse of time prior to the extraction of samples goes to the weight to be afforded the test results...."’ State v. Robinett, 141 Idaho 110, 113 , 106 P.3d 436, 439 (2005) (quoting State v. Stutliff, 97 Idaho 523, 524 , 547 P.2d 1128, 1129 (1976)). 4 .

2013Although Idaho Code § 18-8004 does not impose a timeframe in which the alcohol concentration test must be taken, the Supreme Court has noted that any " 'lapse of time prior to the extraction of samples goes to the weight to be afforded the test results...."’ State v. Robinett, 141 Idaho 110, 113 , 106 P.3d 436, 439 (2005) (quoting State v. Stutliff, 97 Idaho 523, 524 , 547 P.2d 1128, 1129 (1976)). 4 .

11
State v. Robinettgreen
idaho · 2005 · cited in 1 Idaho opinions naming this issue, 2013–2013
2 sentences

2013Although Idaho Code § 18-8004 does not impose a timeframe in which the alcohol concentration test must be taken, the Supreme Court has noted that any " 'lapse of time prior to the extraction of samples goes to the weight to be afforded the test results...."’ State v. Robinett, 141 Idaho 110, 113 , 106 P.3d 436, 439 (2005) (quoting State v. Stutliff, 97 Idaho 523, 524 , 547 P.2d 1128, 1129 (1976)). 4 .

2013Although Idaho Code § 18-8004 does not impose a timeframe in which the alcohol concentration test must be taken, the Supreme Court has noted that any " 'lapse of time prior to the extraction of samples goes to the weight to be afforded the test results...."’ State v. Robinett, 141 Idaho 110, 113 , 106 P.3d 436, 439 (2005) (quoting State v. Stutliff, 97 Idaho 523, 524 , 547 P.2d 1128, 1129 (1976)). 4 .

11
State v. Harmongreen
idahoctapp · 1998 · cited in 1 Idaho opinions naming this issue, 2008–2008
2 sentences

2008See State v. McCormack, 117 Idaho 1009, 1014 , 793 P.2d 682, 687 (1990) ("Although under I.C. § 18-8002(3) a driver has the physical ability to refuse to submit to an evidentiary test, that section did not create a statutory right in a driver to withdraw his implied consent or to refuse to submit to an evidentiary test to determine his blood alcohol level.”); Nickerson, 132 Idaho at 410 , 973 P.2d at 762 (whether defendant's physical cooperation was coerced was superfluous, for defendant had no right to withdraw the statutorily implied consent); State v. Harmon, 131 Idaho 80, 85 , 952 P.2d 402

2008See State v. McCormack, 117 Idaho 1009, 1014 , 793 P.2d 682, 687 (1990) ("Although under I.C. § 18-8002(3) a driver has the physical ability to refuse to submit to an evidentiary test, that section did not create a statutory right in a driver to withdraw his implied consent or to refuse to submit to an evidentiary test to determine his blood alcohol level.”); Nickerson, 132 Idaho at 410 , 973 P.2d at 762 (whether defendant's physical cooperation was coerced was superfluous, for defendant had no right to withdraw the statutorily implied consent); State v. Harmon, 131 Idaho 80, 85 , 952 P.2d 402

11
State v. McCormackgreen
idaho · 1990 · cited in 1 Idaho opinions naming this issue, 2008–2008
2 sentences

2008See State v. McCormack, 117 Idaho 1009, 1014 , 793 P.2d 682, 687 (1990) ("Although under I.C. § 18-8002(3) a driver has the physical ability to refuse to submit to an evidentiary test, that section did not create a statutory right in a driver to withdraw his implied consent or to refuse to submit to an evidentiary test to determine his blood alcohol level.”); Nickerson, 132 Idaho at 410 , 973 P.2d at 762 (whether defendant's physical cooperation was coerced was superfluous, for defendant had no right to withdraw the statutorily implied consent); State v. Harmon, 131 Idaho 80, 85 , 952 P.2d 402

2008See State v. McCormack, 117 Idaho 1009, 1014 , 793 P.2d 682, 687 (1990) ("Although under I.C. § 18-8002(3) a driver has the physical ability to refuse to submit to an evidentiary test, that section did not create a statutory right in a driver to withdraw his implied consent or to refuse to submit to an evidentiary test to determine his blood alcohol level.”); Nickerson, 132 Idaho at 410 , 973 P.2d at 762 (whether defendant's physical cooperation was coerced was superfluous, for defendant had no right to withdraw the statutorily implied consent); State v. Harmon, 131 Idaho 80, 85 , 952 P.2d 402

11
State v. Nickersongreen
idahoctapp · 1999 · cited in 1 Idaho opinions naming this issue, 2008–2008
2 sentences

2008See State v. McCormack, 117 Idaho 1009, 1014 , 793 P.2d 682, 687 (1990) ("Although under I.C. § 18-8002(3) a driver has the physical ability to refuse to submit to an evidentiary test, that section did not create a statutory right in a driver to withdraw his implied consent or to refuse to submit to an evidentiary test to determine his blood alcohol level.”); Nickerson, 132 Idaho at 410 , 973 P.2d at 762 (whether defendant's physical cooperation was coerced was superfluous, for defendant had no right to withdraw the statutorily implied consent); State v. Harmon, 131 Idaho 80, 85 , 952 P.2d 402

2008See State v. McCormack, 117 Idaho 1009, 1014 , 793 P.2d 682, 687 (1990) ("Although under I.C. § 18-8002(3) a driver has the physical ability to refuse to submit to an evidentiary test, that section did not create a statutory right in a driver to withdraw his implied consent or to refuse to submit to an evidentiary test to determine his blood alcohol level.”); Nickerson, 132 Idaho at 410 , 973 P.2d at 762 (whether defendant's physical cooperation was coerced was superfluous, for defendant had no right to withdraw the statutorily implied consent); State v. Harmon, 131 Idaho 80, 85 , 952 P.2d 402

11
State v. Wooleryred
idaho · 1989 · cited in 1 Idaho opinions naming this issue, 1999–1999
2 sentences

1999Schmerber v. California, 384 U.S. 757 , 86 S.Ct. 1826 , 16 L.Ed.2d 908 (1966); State v. Woolery, 116 Idaho 368, 370 , 775 P.2d 1210, 1212 (1989); State v. Curtis, 106 Idaho 483 , 680 P.2d 1383 (Ct.App. 1984).

1999Schmerber v. California, 384 U.S. 757 , 86 S.Ct. 1826 , 16 L.Ed.2d 908 (1966); State v. Woolery, 116 Idaho 368, 370 , 775 P.2d 1210, 1212 (1989); State v. Curtis, 106 Idaho 483 , 680 P.2d 1383 (Ct.App. 1984).

11
State v. Tategreen
idahoctapp · 1992 · cited in 1 Idaho opinions naming this issue, 1994–1994
2 sentences

1994See State v. Tate, 122 Idaho 366 , 834 P.2d 883 (Ct.App.1992).

1994See State v. Tate, 122 Idaho 366 , 834 P.2d 883 (Ct.App.1992).

11
Mason v. State, Dept. of Law Enforcementgreen
idahoctapp · 1982 · cited in 1 Idaho opinions naming this issue, 1993–1993
2 sentences

1993See, e.g., Mason v. State, Dept. of Law Enforcement, 103 Idaho 748 , 653 P.2d 803 (Ct.App.1982).

1993See, e.g., Mason v. State, Dept. of Law Enforcement, 103 Idaho 748 , 653 P.2d 803 (Ct.App.1982).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (11)

CaseCitedYears
Matter of Beem green
idahoctapp · 1991
2 sentences

2021Beem, 119 Idaho at 290 , 805 P.2d at 496 .

2021Beem, 119 Idaho at 290 , 805 P.2d at 496 .

12021–2021
Matter of Smith green
idahoctapp · 1989
1 sentence

2014Id. (citing State v. Clark, 425 N.W.2d 347 (Neb. 1988)).

12014–2014
State v. Clark green
neb · 1988
1 sentence

2014Id. (citing State v. Clark, 425 N.W.2d 347 (Neb. 1988)).

12014–2014
State v. Schmoll green
idahoctapp · 2007
2 sentences

2013Schmoll, 144 Idaho at 804 , 172 P.3d at 559 (citing I.C. § 18-8004(2), (3)).

2013Schmoll, 144 Idaho at 804 , 172 P.3d at 559 (citing I.C. § 18-8004(2), (3)).

12013–2013
State v. Carr green
idahoctapp · 1995
2 sentences

2010Id. at 184-85 , 911 P.2d at 777-78 .

2010Id. at 184-85 , 911 P.2d at 777-78 .

12010–2010
State v. Alford green
idahoctapp · 2004
2 sentences

2007Alford, 139 Idaho at 597 , 83 P.3d at 141 .

2007Alford, 139 Idaho at 597 , 83 P.3d at 141 .

12007–2007
Schmerber v. California green
scotus · 1966
2 sentences

1999Schmerber v. California, 384 U.S. 757 , 86 S.Ct. 1826 , 16 L.Ed.2d 908 (1966); State v. Woolery, 116 Idaho 368, 370 , 775 P.2d 1210, 1212 (1989); State v. Curtis, 106 Idaho 483 , 680 P.2d 1383 (Ct.App. 1984).

1999Schmerber v. California, 384 U.S. 757 , 86 S.Ct. 1826 , 16 L.Ed.2d 908 (1966); State v. Woolery, 116 Idaho 368, 370 , 775 P.2d 1210, 1212 (1989); State v. Curtis, 106 Idaho 483 , 680 P.2d 1383 (Ct.App. 1984).

11999–1999
State v. Curtis green
idahoctapp · 1984
2 sentences

1999Schmerber v. California, 384 U.S. 757 , 86 S.Ct. 1826 , 16 L.Ed.2d 908 (1966); State v. Woolery, 116 Idaho 368, 370 , 775 P.2d 1210, 1212 (1989); State v. Curtis, 106 Idaho 483 , 680 P.2d 1383 (Ct.App. 1984).

1999Schmerber v. California, 384 U.S. 757 , 86 S.Ct. 1826 , 16 L.Ed.2d 908 (1966); State v. Woolery, 116 Idaho 368, 370 , 775 P.2d 1210, 1212 (1989); State v. Curtis, 106 Idaho 483 , 680 P.2d 1383 (Ct.App. 1984).

11999–1999
State v. Knoll green
idahoctapp · 1986
2 sentences

1994As we have previously noted, evidence of impairment is not probative for the purpose of challenging an alcohol concentration test “unless an adequate foundation [is] laid to show a correlation between the alleged blood-alcohol level and the likely manifestation of specific symptoms.” Knoll, 110 Idaho at 682 n. 3, 718 P.2d at 593 n. 3.

1994As we have previously noted, evidence of impairment is not probative for the purpose of challenging an alcohol concentration test “unless an adequate foundation [is] laid to show a correlation between the alleged blood-alcohol level and the likely manifestation of specific symptoms.” Knoll, 110 Idaho at 682 n. 3, 718 P.2d at 593 n. 3.

11994–1994
State v. Andrus green
idahoctapp · 1990
2 sentences

1992Andrus, 118 Idaho at 714 , 800 P.2d at 110 . 2 Applying Andrus , we hold that the district court did not abuse its discretion in refusing to allow Tate’s proffered expert testimony about his BAC and any opinion based thereon.

1992Andrus, 118 Idaho at 714 , 800 P.2d at 110 . 2 Applying Andrus , we hold that the district court did not abuse its discretion in refusing to allow Tate’s proffered expert testimony about his BAC and any opinion based thereon.

11992–1992
Matter of Griffiths green
idaho · 1987
2 sentences

1991The district court held that the magistrate had no discretion to suspend a driver’s license for less than 180 days, and, relying on In re Griffith’s License, 113 Idaho 364 , 744 P.2d 92 (1987), ruled that Beem’s refusal to take the alcohol concentration test could not serve as a basis for suspending his license because the officer did not first correctly advise Beem of his rights and duties under I.C. § 18-8002(3).

1991The district court held that the magistrate had no discretion to suspend a driver’s license for less than 180 days, and, relying on In re Griffith’s License, 113 Idaho 364 , 744 P.2d 92 (1987), ruled that Beem’s refusal to take the alcohol concentration test could not serve as a basis for suspending his license because the officer did not first correctly advise Beem of his rights and duties under I.C. § 18-8002(3).

11991–1991

Statutes the citing opinions construe

ID § Idaho Code § 18-8004 (11) ID § Idaho Code § 18-8002 (9) ID § Idaho Code § 18-8004C (4) ID § Idaho Code § 18-8006 (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

MD 23 (1993–2024) MN 17 (1987–2015) ID 13 (1991–2021) KS 10 (1994–2021) GA 5 (2002–2015) NH 3 (2008–2018) HI 3 (2002–2017) TX 3 (1986–2015) WA 2 (1996–1996) WI 2 (1986–2022)

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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