urine test in Illinois

2018The State also argues that cases Sykes cites to support a finding that the urine tests results should be excluded—including Missouri v. McNeely, 569 U.S. 141 (2013), and Schmerber, 384 U.S. 757—involved blood tests ordered by the police and have no bearing, since the Evanston police neither ordered nor asked hospital staff to perform a urine test on Sykes. ¶ 26 Sykes argues the officers were state actors when they held her down while a nurse extracted urine for a test used as evidence against her.

2018The State also argues that cases Sykes cites to support a finding that the urine tests results should be excluded—including Missouri v. McNeely, 569 U.S. 141 (2013), and Schmerber, 384 U.S. 757—involved blood tests ordered by the police and have no bearing, since the Evanston police neither ordered nor asked hospital staff to perform a urine test on Sykes. ¶ 26 Sykes argues the officers were state actors when they held her down while a nurse extracted urine for a test used as evidence against her.

2018The State also argues that cases Sykes cites to support a finding that the urine tests results should be excluded—including Missouri v. McNeely, 569 U.S. 141 (2013), and Schmerber, 384 U.S. 757—involved blood tests ordered by the police and have no bearing, since the Evanston police neither ordered nor asked hospital staff to perform a urine test on Sykes. ¶ 26 Sykes argues the officers were state actors when they held her down while a nurse extracted urine for a test used as evidence against her.

2018The State also argues that cases Sykes cites to support a finding that the urine tests results should be excluded—including Missouri v. McNeely, 569 U.S. 141 (2013), and Schmerber, 384 U.S. 757—involved blood tests ordered by the police and have no bearing, since the Evanston police neither ordered nor asked hospital staff to perform a urine test on Sykes. ¶ 26 Sykes argues the officers were state actors when they held her down while a nurse extracted urine for a test used as evidence against her.

2021The Court explained that the process of collecting a urine sample implicates privacy interests and that a urine test, like a blood test, “can reveal a host of private medical facts.” Id.

2019The Court explained that the process of collecting a urine sample implicates privacy interests and that a urine test, like a blood test, “can - 25 - reveal a host of private medical facts.” Id.

2012Id. at 613-14 , 225 Ill.Dec. 752 , 684 N.E.2d 437 . ¶ 16 The appellate court reversed, holding that the trial court erred in assuming that the administration of the urine test required independent probable cause to believe that the defendant had used drugs.

2012Id. at 613-14 , 225 Ill.Dec. 752 , 684 N.E.2d 437 . ¶ 16 The appellate court reversed, holding that the trial court erred in assuming that the administration of the urine test required independent probable cause to believe that the defendant had used drugs.

2026App. 3d 854, 861 (1996), rev’d on other grounds, 179 Ill. 2d 319 (1997); see People v. Kuehner, 2022 IL App (4th) 200325, ¶ 132 (“ ‘We are exceptionally reluctant to reverse a trial court’s decision based on an argument raised on appeal that the trial court never heard below.’ ”). ¶ 42 We find the only foundational challenge properly raised and preserved for review is whether the trial court erred when it allowed the urine test results into evidence despite the absence of evidence concerning how the samples got from Rockford to Chicago.

2026“Even where the chain of custody has a missing link, trial courts have properly admitted evidence where there was testimony which sufficiently described the condition of the evidence when delivered which matched the description of the evidence when examined.” (Internal quotation marks omitted.) Id. at 467-68 . - 16 - ¶ 45 We cannot say the trial court’s ruling to allow the urine test results into evidence despite the absence of evidence of how the samples got from Rockford to Chicago was arbitrary, fanciful, or unreasonable or that no reasonable person would agree with the court’s position.

2026People v. Patterson, 2014 IL 115102 , ¶ 114.

2021Therefore, given the similarities between the medical blood draw and the urine test in Wuckert, we apply our reasoning in Wuckert to the case at hand and determine 8 Although defendant has not made a similar admission before the trial court, Wuckert’s analysis and holding was not predicated on the defendant’s concession. - 18 - 2021 IL App (2d) 190868 that section 11-501.4-1 did not convert any medical staff into State agents. 9 Because defendant has therefore failed to show that the medical blood draw was procured by State action, she has failed to make a prima facie case that the draw violat

2020Thus, the delay in arresting defendant was far shorter than 16 months. - 11 - 2020 IL App (2d) 190532 No. 2-19-0532 Cite as: People v. Patel, 2020 IL App (2d) 190532 Decision Under Review: Appeal from the Circuit Court of Du Page County, No. 16-CF- 414; the Hon.

2020Thus, the delay in arresting defendant was far shorter than 16 months. - 11 - 2020 IL App (2d) 190532 No. 2-19-0532 Cite as: People v. Patel, 2020 IL App (2d) 190532 Decision Under Review: Appeal from the Circuit Court of Du Page County, No. 16-CF- 414; the Hon.

1978In fact, we believe that a urine test was not even required in this case inasmuch as drug addiction goes only to the credibility of the witness, (People v. Dixon (1961), 22 Ill. 2d 513 , 177 N.E.2d 224 ), and here, the jury had sufficient facts to determine Stewart’s credibility.

1978In fact, we believe that a urine test was not even required in this case inasmuch as drug addiction goes only to the credibility of the witness, (People v. Dixon (1961), 22 Ill. 2d 513 , 177 N.E.2d 224 ), and here, the jury had sufficient facts to determine Stewart’s credibility.