accurate test (California) · Go Syfert
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accurate test in California

11 California opinions name it 2 courts 1969–2026 1 in the last five years

The cases below were cited by California 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 (8)

CaseFollowedCited
Rick Koenig v. Daniel Vannelli Douglas Trudeaugreen
ca9 · 1992 · cited in 2 California opinions naming this issue, 2002–2002
2 sentences

2002(Penrod v. State, supra, at p. 655; Koenig v. Vannelli (9th Cir. 1992) 971 F.2d 422, 422-423 [Ninth Circuit rejected a challenge to the use of the ADX Abbott by state prison officials in their random drug testing program].) The ADX Abbott drug analyzer is used to test for cocaine in urine samples.

2002But the acceptance of the scientific method does not depend on who operates the machinery. ( People v. Cooper (1991) 53 Cal.3d 771, 814 , 281 Cal.Rptr. 90 , 809 P.2d 865 .) The ADX Abbott has reached a "level of general acceptance" in the scientific community. ( Carter v. State, supra, 706 N.E.2d at p. 554 .) Courts have relied on its urine test results to detect probation violations. ( Penrod v. State (Ind.Ct.App. 1993) 611 N.E.2d 653, 654-655 .) It is an accurate test for the presence of marijuana in biological fluids. ( Penrod v. State, supra, at p. 655; Koenig v. Vannelli (9th Cir.1992) 97

22
Robinson v. U-Haul Co. of Californiagreen
calctapp · 2016 · cited in 1 California opinions naming this issue, 2026–2026
1 sentence

2026(See Cal. Rules of Court (CRC), rule 3.1702; see also Robinson v. U-Haul Co. of California (2016) 4 Cal.App.5th 304 , 326–327 [court discretion to extend time for fee motion].) Diamond timely appealed within 60 days after notice of entry of the second amended judgment memorializing the attorney 4 At oral argument, Accurate noted that Diamond proposed the seven-percent judgment “out of the blue,” without “instruction, not part of an order, not part of a motion.” In his attempt to defend the maneuver, Diamond’s counsel conceded that a court can fix its own clerical error. 7 fee award. (§ 904.1,

11
People v. Thomasgreen
calctapp · 2007 · cited in 1 California opinions naming this issue, 2014–2014
1 sentence

2014Citing People v. Thomas (2007) 146 Cal.App.4th 1278, 1281-1282 (Thomas) (disapproved on other grounds in People v. Shockley (2013) 58 Cal.4th 400 ), the Attorney General asserts defendant’s failure to request the instruction waived his right to raise it on appeal.

11
People v. Pockgreen
calctapp · 1993 · cited in 1 California opinions naming this issue, 2010–2010
2 sentences

2010(CALJIC No. 3.40.) This instruction is required in cases in which one cause of death is alleged but the evidence suggests that an independent supervening act, separate from the defendant's act, may have brought about the death. ( People v. Pock (1993) 19 Cal.App.4th 1263, 1276 [ 23 Cal.Rptr.2d 900 ].) In cases in which there may be concurrent causes of death, however, the substantial factor test embodied by CALJIC No. 3.41 provides the accurate standard, because it avoids the possibility of jury confusion and prevents each defendant from escaping responsibility when the conduct of one or more

2010(CALJIC No. 3.40.) This instruction is required in cases in which one cause of death is alleged but the evidence suggests that an independent supervening act, separate from the defendant's act, may have brought about the death. ( People v. Pock (1993) 19 Cal.App.4th 1263, 1276 [ 23 Cal.Rptr.2d 900 ].) In cases in which there may be concurrent causes of death, however, the substantial factor test embodied by CALJIC No. 3.41 provides the accurate standard, because it avoids the possibility of jury confusion and prevents each defendant from escaping responsibility when the conduct of one or more

11
Frye v. United Statesred
cadc · 1923 · cited in 1 California opinions naming this issue, 2002–2002
1 sentence

2002(Penrod v. State, supra, at p. 655; Koenig v. Vannelli (9th Cir. 1992) 971 F.2d 422, 422-423 [Ninth Circuit rejected a challenge to the use of the ADX Abbott by state prison officials in their random drug testing program].) The ADX Abbott drug analyzer is used to test for cocaine in urine samples.

11
People v. Whartongreen
cal · 1991 · cited in 1 California opinions naming this issue, 2000–2000
2 sentences

2000Defendant contends the trial court erred in refusing his requested instruction and in failing sua sponte to give an accurate instruction on the burden of proof or persuasion as to mitigating circumstances, which would have entailed instructing the jury as to the substantial evidence standard (see People v. Wharton (1991) 53 Cal.3d 522, 600-601 [ 280 Cal.Rptr. 631 , 809 P.2d 290 ]).

2000Defendant contends the trial court erred in refusing his requested instruction and in failing sua sponte to give an accurate instruction on the burden of proof or persuasion as to mitigating circumstances, which would have entailed instructing the jury as to the substantial evidence standard (see People v. Wharton (1991) 53 Cal.3d 522, 600-601 [ 280 Cal.Rptr. 631 , 809 P.2d 290 ]).

11
People v. Welchgreen
cal · 1999 · cited in 1 California opinions naming this issue, 2000–2000
2 sentences

2000We rejected a similar contention in People v. Welch (1999) 20 Cal.4th 701, 767 [ 85 Cal.Rptr.2d 203 , 976 P.2d 754 ], finding no reason to believe that a jury, given instructions that aggravating factors must be proven beyond a reasonable doubt, but told nothing about mitigating factors, would think it could consider mitigating circumstances only if proven beyond a reasonable doubt.

2000We rejected a similar contention in People v. Welch (1999) 20 Cal.4th 701, 767 [ 85 Cal.Rptr.2d 203 , 976 P.2d 754 ], finding no reason to believe that a jury, given instructions that aggravating factors must be proven beyond a reasonable doubt, but told nothing about mitigating factors, would think it could consider mitigating circumstances only if proven beyond a reasonable doubt.

11
California v. Ramosgreen
scotus · 1983 · cited in 1 California opinions naming this issue, 1988–1988
2 sentences

1988The United States Supreme Court found no federal Constitutional error in an accurate instruction bringing to the jury's attention the possibility that the defendant might be returned to society. ( California v. Ramos, supra, 463 U.S. 992, 1003-1013 [ 77 L.Ed.2d 1171, 1182-1183 ].) This court nonetheless invalidated this instruction on state constitutional grounds, concluding that it invited the jury to be influenced by speculative and improper considerations.

1988The United States Supreme Court found no federal Constitutional error in an accurate instruction bringing to the jury's attention the possibility that the defendant might be returned to society. ( California v. Ramos, supra, 463 U.S. 992, 1003-1013 [ 77 L.Ed.2d 1171, 1182-1183 ].) This court nonetheless invalidated this instruction on state constitutional grounds, concluding that it invited the jury to be influenced by speculative and improper considerations.

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (13)

CaseCitedYears
Penrod v. State green
indctapp · 1993
2 sentences

2002(Penrod v. State (Ind.Ct.App. 1993) 611 N.E.2d 653, 654-655 .) It is an accurate test for the presence of marijuana in biological fluids.

2002But the acceptance of the scientific method does not depend on who operates the machinery. ( People v. Cooper (1991) 53 Cal.3d 771, 814 , 281 Cal.Rptr. 90 , 809 P.2d 865 .) The ADX Abbott has reached a "level of general acceptance" in the scientific community. ( Carter v. State, supra, 706 N.E.2d at p. 554 .) Courts have relied on its urine test results to detect probation violations. ( Penrod v. State (Ind.Ct.App. 1993) 611 N.E.2d 653, 654-655 .) It is an accurate test for the presence of marijuana in biological fluids. ( Penrod v. State, supra, at p. 655; Koenig v. Vannelli (9th Cir.1992) 97

22002–2002
In Re Marriage of Braud green
calctapp · 1996
1 sentence

2019As noted, to rebut the community property presumption by indirect tracing, the record must show that community income was depleted when the asset in question was acquired, and that separate property funds were actually used to make payments on the asset. ( Braud, supra, 45 Cal.App.4th at pp. 823-824.) Addleman's opinion that community income between 1996 and 2001 was "minimal" is insufficient to satisfy George's burden of showing that when he paid the $20,000 to his sister for the property and that when he made payments on the property between 1997 and 2001, all community income was exhausted

12019–2019
People v. Beltran green
cal · 2013
1 sentence

2016(Beltran, supra, 56 Cal.4th at p. 949 .) The prosecutor misstated the law during argument.

12016–2016
People v. Shockley green
cal · 2013
1 sentence

2014Citing People v. Thomas (2007) 146 Cal.App.4th 1278, 1281-1282 (Thomas) (disapproved on other grounds in People v. Shockley (2013) 58 Cal.4th 400 ), the Attorney General asserts defendant’s failure to request the instruction waived his right to raise it on appeal.

12014–2014
Richard W. Spence v. Hal Farrier green
ca8 · 1986
1 sentence

2002But jurisdictions including the Ninth Circuit have accepted its validity for almost a decade. ( Koenig v. Vannelli, supra, 971 F.2d at pp. 422-423; Penrod v. State, supra, 611 N.E.2d at pp. 654-655.) Both the ADX Abbott and the older EMIT (enzyme immunoassay test) use the well-accepted immunoassay scientific technique to detect drugs in urine. ( Koenig, at p. 422, citing "Urine Testing in the Detection of Drugs of Abuse" 148 Archives of Internal Medicine 2407 (November 1988); Penrod , at p. 654; Carter v. State, supra, 706 N.E.2d at p. 554 ; Spence v. Farrier (8th Cir.1986) 807 F.2d 753, 754-7

12002–2002
People v. Cooper green
cal · 1991
2 sentences

2002But the acceptance of the scientific method does not depend on who operates the machinery. ( People v. Cooper (1991) 53 Cal.3d 771, 814 , 281 Cal.Rptr. 90 , 809 P.2d 865 .) The ADX Abbott has reached a "level of general acceptance" in the scientific community. ( Carter v. State, supra, 706 N.E.2d at p. 554 .) Courts have relied on its urine test results to detect probation violations. ( Penrod v. State (Ind.Ct.App. 1993) 611 N.E.2d 653, 654-655 .) It is an accurate test for the presence of marijuana in biological fluids. ( Penrod v. State, supra, at p. 655; Koenig v. Vannelli (9th Cir.1992) 97

2002But the acceptance of the scientific method does not depend on who operates the machinery. ( People v. Cooper (1991) 53 Cal.3d 771, 814 , 281 Cal.Rptr. 90 , 809 P.2d 865 .) The ADX Abbott has reached a "level of general acceptance" in the scientific community. ( Carter v. State, supra, 706 N.E.2d at p. 554 .) Courts have relied on its urine test results to detect probation violations. ( Penrod v. State (Ind.Ct.App. 1993) 611 N.E.2d 653, 654-655 .) It is an accurate test for the presence of marijuana in biological fluids. ( Penrod v. State, supra, at p. 655; Koenig v. Vannelli (9th Cir.1992) 97

12002–2002
Carter v. State green
ind · 1999
2 sentences

2002But the acceptance of the scientific method does not depend on who operates the machinery. ( People v. Cooper (1991) 53 Cal.3d 771, 814 , 281 Cal.Rptr. 90 , 809 P.2d 865 .) The ADX Abbott has reached a "level of general acceptance" in the scientific community. ( Carter v. State, supra, 706 N.E.2d at p. 554 .) Courts have relied on its urine test results to detect probation violations. ( Penrod v. State (Ind.Ct.App. 1993) 611 N.E.2d 653, 654-655 .) It is an accurate test for the presence of marijuana in biological fluids. ( Penrod v. State, supra, at p. 655; Koenig v. Vannelli (9th Cir.1992) 97

2002But jurisdictions including the Ninth Circuit have accepted its validity for almost a decade. ( Koenig v. Vannelli, supra, 971 F.2d at pp. 422-423; Penrod v. State, supra, 611 N.E.2d at pp. 654-655.) Both the ADX Abbott and the older EMIT (enzyme immunoassay test) use the well-accepted immunoassay scientific technique to detect drugs in urine. ( Koenig, at p. 422, citing "Urine Testing in the Detection of Drugs of Abuse" 148 Archives of Internal Medicine 2407 (November 1988); Penrod , at p. 654; Carter v. State, supra, 706 N.E.2d at p. 554 ; Spence v. Farrier (8th Cir.1986) 807 F.2d 753, 754-7

12002–2002
People v. Toran green
illappct · 1991
2 sentences

2002But the acceptance of the scientific method does not depend on who operates the machinery. ( People v. Cooper (1991) 53 Cal.3d 771, 814 , 281 Cal.Rptr. 90 , 809 P.2d 865 .) The ADX Abbott has reached a "level of general acceptance" in the scientific community. ( Carter v. State, supra, 706 N.E.2d at p. 554 .) Courts have relied on its urine test results to detect probation violations. ( Penrod v. State (Ind.Ct.App. 1993) 611 N.E.2d 653, 654-655 .) It is an accurate test for the presence of marijuana in biological fluids. ( Penrod v. State, supra, at p. 655; Koenig v. Vannelli (9th Cir.1992) 97

2002But the acceptance of the scientific method does not depend on who operates the machinery. ( People v. Cooper (1991) 53 Cal.3d 771, 814 , 281 Cal.Rptr. 90 , 809 P.2d 865 .) The ADX Abbott has reached a "level of general acceptance" in the scientific community. ( Carter v. State, supra, 706 N.E.2d at p. 554 .) Courts have relied on its urine test results to detect probation violations. ( Penrod v. State (Ind.Ct.App. 1993) 611 N.E.2d 653, 654-655 .) It is an accurate test for the presence of marijuana in biological fluids. ( Penrod v. State, supra, at p. 655; Koenig v. Vannelli (9th Cir.1992) 97

12002–2002
Decker v. Department of Motor Vehicles green
cal · 1972
2 sentences

1981(Decker v. Department of Motor Vehicles (1972) 6 Cal.3d 903 [ 101 Cal.Rptr. 387 , 495 P.2d 1307 ]; Giomi v. Department of Motor Vehicles (1971) 15 Cal.App.3d 905 [ 93 Cal.Rptr. 613 ].) However, when the specific and accurate warning is given, the later use of less accurate predictions of consequences does not invalidate the advisement.

1981(Decker v. Department of Motor Vehicles (1972) 6 Cal.3d 903 [ 101 Cal.Rptr. 387 , 495 P.2d 1307 ]; Giomi v. Department of Motor Vehicles (1971) 15 Cal.App.3d 905 [ 93 Cal.Rptr. 613 ].) However, when the specific and accurate warning is given, the later use of less accurate predictions of consequences does not invalidate the advisement.

11981–1981
Smith v. Department of Motor Vehicles green
calctapp · 1969
1 sentence

1981(Smith v. Department of Motor Vehicles, supra, 1 Cal.App.3d at p. 503 .) In view of the strong public policy which led to the adoption of the statute and the obligation of courts to construe it liberally to effect its objectives (see Bush v. Bright (1968) 264 Cal.App.2d 788 [ 71 Cal.Rptr. 123 ]), we agree with the trial court that the sequence of advisements in this case was of no consequence.

11981–1981
Giomi v. Department of Motor Vehicles green
calctapp · 1971
2 sentences

1981(Decker v. Department of Motor Vehicles (1972) 6 Cal.3d 903 [ 101 Cal.Rptr. 387 , 495 P.2d 1307 ]; Giomi v. Department of Motor Vehicles (1971) 15 Cal.App.3d 905 [ 93 Cal.Rptr. 613 ].) However, when the specific and accurate warning is given, the later use of less accurate predictions of consequences does not invalidate the advisement.

1981(Decker v. Department of Motor Vehicles (1972) 6 Cal.3d 903 [ 101 Cal.Rptr. 387 , 495 P.2d 1307 ]; Giomi v. Department of Motor Vehicles (1971) 15 Cal.App.3d 905 [ 93 Cal.Rptr. 613 ].) However, when the specific and accurate warning is given, the later use of less accurate predictions of consequences does not invalidate the advisement.

11981–1981
Bush v. Bright green
calctapp · 1968
2 sentences

1981(Smith v. Department of Motor Vehicles, supra, 1 Cal.App.3d at p. 503 .) In view of the strong public policy which led to the adoption of the statute and the obligation of courts to construe it liberally to effect its objectives (see Bush v. Bright (1968) 264 Cal.App.2d 788 [ 71 Cal.Rptr. 123 ]), we agree with the trial court that the sequence of advisements in this case was of no consequence.

1981(Smith v. Department of Motor Vehicles, supra, 1 Cal.App.3d at p. 503 .) In view of the strong public policy which led to the adoption of the statute and the obligation of courts to construe it liberally to effect its objectives (see Bush v. Bright (1968) 264 Cal.App.2d 788 [ 71 Cal.Rptr. 123 ]), we agree with the trial court that the sequence of advisements in this case was of no consequence.

11981–1981
Janusch v. Department of Motor Vehicles green
calctapp · 1969
1 sentence

1969We have concluded, as in Janusch v. Department of Motor Vehicles, supra, 276 Cal.App.2d 193 , that the use of the word “chances” when coupled with the specific prior instruction did not vitiate compliance with section 13353.

11969–1969

Statutes the citing opinions construe

CA § Cal. Penal Code § 187 (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

IL 51 (1875–2025) FL 45 (1981–2020) UT 24 (1969–2024) MN 19 (1900–2024) NY 15 (1914–2014) MI 14 (1976–2024) CA 11 (1969–2026) WA 11 (1926–2021) PA 11 (1955–2020) CO 9 (1929–2001) OH 8 (1934–2021) NV 8 (1970–2019) TX 7 (1937–2015) CT 6 (1935–2023) TN 6 (2000–2025) KS 6 (1920–1991) KY 5 (1928–2020) IA 5 (1945–1999) AL 5 (1884–2001) MS 5 (1986–2003) WI 5 (1887–2007) GA 4 (1946–1980) MA 4 (1979–2018) WV 4 (1996–2020) NJ 4 (2011–2024) HI 3 (1999–2002) IN 3 (1987–2025) MO 3 (1956–2018) VT 3 (2010–2013) MD 3 (1981–1997) VA 2 (1985–2013) OR 2 (1917–1998) RI 2 (2001–2021) NM 2 (1998–2012) WY 2 (1978–1994)

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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