portable breath test (Indiana) · Go Syfert
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portable breath test in Indiana

11 Indiana opinions name it 1 courts 2003–2026 2 in the last five years

The cases below were cited by Indiana 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 (5)

CaseFollowedCited
State v. Whitneygreen
indctapp · 2008 · cited in 2 Indiana opinions naming this issue, 2016–2020
2 sentences

2020Adams v. State, 960 N.E.2d 793, 798 (Ind. 2012). [22] Pedigo relies on State v. Whitney, 889 N.E.2d 823 (Ind. Ct. App. 2008) for his contention that where a portable breath test result is negative and there is no probable cause for intoxication, police may not seek a blood sample.

2016Therefore, according to the plain language of the statute, when there is an accident resulting in serious bodily injury or death, the officer can choose what test to offer the driver first: (1) a portable breath test, the results of which are generally inadmissible at trial, State v. Whitney, 889 N.E.2d 823, 828 (Ind.Ct.App.2008), or (2) á chemical test, the results of which are admissible at trial if certain requirements are met, see Bisard, 973 N.E.2d at 1233 .

12
Koske v. Townsend Engineering Co.green
ind · 1990 · cited in 1 Indiana opinions naming this issue, 2020–2020
1 sentence

2020See State v. Hardy, 7 N.E.3d 396, 401 (Ind. Ct. App. 2014) (stating that dicta refers to statements that a court makes that are not necessary in the determination of the issues presented, are not binding, and do not become law, although it may be considered persuasive) (citing Koske v. Townsend Engineering Co., 551 N.E.2d 437, 443 (Ind. 1990)). [23] Both parties also cite to Mannix v State, 54 N.E.3d 1002 (Ind. Ct. App. 2016) in their arguments, but such reliance is misplaced.

11
Morgan Mannix v. State of Indianagreen
indctapp · 2016 · cited in 1 Indiana opinions naming this issue, 2020–2020
2 sentences

2020See State v. Hardy, 7 N.E.3d 396, 401 (Ind. Ct. App. 2014) (stating that dicta refers to statements that a court makes that are not necessary in the determination of the issues presented, are not binding, and do not become law, although it may be considered persuasive) (citing Koske v. Townsend Engineering Co., 551 N.E.2d 437, 443 (Ind. 1990)). [23] Both parties also cite to Mannix v State, 54 N.E.3d 1002 (Ind. Ct. App. 2016) in their arguments, but such reliance is misplaced.

2020Mannix, 54 N.E.3d at 1005 .

11
Adams v. Stategreen
ind · 2012 · cited in 1 Indiana opinions naming this issue, 2020–2020
1 sentence

2020Adams v. State, 960 N.E.2d 793, 798 (Ind. 2012). [22] Pedigo relies on State v. Whitney, 889 N.E.2d 823 (Ind. Ct. App. 2008) for his contention that where a portable breath test result is negative and there is no probable cause for intoxication, police may not seek a blood sample.

11
State of Indiana v. David Lott Hardygreen
indctapp · 2014 · cited in 1 Indiana opinions naming this issue, 2020–2020
1 sentence

2020See State v. Hardy, 7 N.E.3d 396, 401 (Ind. Ct. App. 2014) (stating that dicta refers to statements that a court makes that are not necessary in the determination of the issues presented, are not binding, and do not become law, although it may be considered persuasive) (citing Koske v. Townsend Engineering Co., 551 N.E.2d 437, 443 (Ind. 1990)). [23] Both parties also cite to Mannix v State, 54 N.E.3d 1002 (Ind. Ct. App. 2016) in their arguments, but such reliance is misplaced.

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (9)

CaseCitedYears
Hannoy v. State green
indctapp · 2003
2 sentences

2026And, while she first offered Blackburn a portable breath test that returned negative results for alcohol intoxication, there is also no question that Blackburn then twice consented to a chemical test by way of the blood draw. [16] Nonetheless, relying on a panel opinion from our Court in Hannoy v. State, Blackburn contends that Deputy Milholland needed probable cause that he was under the influence of a controlled substance before she could offer him a chemical test. 789 N.E.2d 977 (Ind. Ct. App.), aff’d on reh’g, 793 N.E.2d 1109 (Ind. Ct. App. 2003), trans. denied.

2003However, "[nlothing in Indiana Code § 9-80-7 authorizes an officer to forcibly take a blood sample if actual consent to a chemical test is not obtained." Hannoy, 789 N.E.2d at 983 .

22003–2026
State of Indiana v. David Bisard green
indctapp · 2012
2 sentences

2025However, all chemical tests must be administered within three (3) hours after the fatal accident or the accident involving serious bodily injury. (c) It is not necessary for a law enforcement officer to offer a portable breath test or chemical test to an unconscious person. 7 Ind. Code § 9-30-7-1 (b) provides: “As used in this chapter, ‘fatal accident’ means an accident, a collision, or other occurrence that involves at least one (1) vehicle and that results in: (1) death; or (2) bodily injury that gives a law enforcement officer reason to believe that the death of at least one (1) person is i

2016Therefore, according to the plain language of the statute, when there is an accident resulting in serious bodily injury or death, the officer can choose what test to offer the driver first: (1) a portable breath test, the results of which are generally inadmissible at trial, State v. Whitney, 889 N.E.2d 823, 828 (Ind.Ct.App.2008), or (2) á chemical test, the results of which are admissible at trial if certain requirements are met, see Bisard, 973 N.E.2d at 1233 .

22016–2025
Flanagan v. State green
indctapp · 2005
2 sentences

2019Id. [15] Before driving Flanagan to the police station, the deputy took Flanagan to his vehicle so he could retrieve some of his personal belongings.

2018Id.

22018–2019
Will Thomas v. State of Indiana green
ind · 2017
1 sentence

2026Id. [14] Indiana Code section 9-30-7-3(a) requires a law enforcement officer to “offer a portable breath test or chemical test to any person who the officer has reason to believe operated a vehicle that was involved in a fatal accident or an accident 2 Blackburn lodged no objection to any portion of Holderman’s testimony, and Blackburn specifically did not challenge Holderman’s competence to testify regarding the child’s viability.

12026–2026
Hannoy v. State green
indctapp · 2003
1 sentence

2026And, while she first offered Blackburn a portable breath test that returned negative results for alcohol intoxication, there is also no question that Blackburn then twice consented to a chemical test by way of the blood draw. [16] Nonetheless, relying on a panel opinion from our Court in Hannoy v. State, Blackburn contends that Deputy Milholland needed probable cause that he was under the influence of a controlled substance before she could offer him a chemical test. 789 N.E.2d 977 (Ind. Ct. App.), aff’d on reh’g, 793 N.E.2d 1109 (Ind. Ct. App. 2003), trans. denied.

12026–2026
Eduardo Cruz-Salazar v. State of Indiana green
ind · 2016
1 sentence

2020The defendant was arrested for public intoxication after Court of Appeals of Indiana | Memorandum Decision 19A-CR-2553 | May 29, 2020 Page 7 of 17 registering 0.184 on a portable breath test and during a search incident to the arrest, the defendant was found in possession of cocaine. [13] In concluding that the police officer’s warrantless entry into the vehicle was permissible under both the United States and Indiana Constitutions, our Supreme Court held that “the report of a stationary vehicle that had been running for thirty minutes, in the early hours of a cold December morning,” was suffi

12020–2020
Wilson v. State green
ind · 2001
1 sentence

2014Id.

12014–2014
State v. Johnson green
indctapp · 1987
1 sentence

2013Therefore, Gilbert’s seizure and removal from the scene did not violate his rights under the Fourth Amendment. 2 Second, the trial court believed that cases such as Johnson, supra, were inapplicable because they dealt with probable cause justifying searches, not seizures.

12013–2013
Schlesinger v. State green
indctapp · 2004
1 sentence

2004Id. at 968 . j - In this case, Deputy Tyler did not properly attain Wiggins' consent to a portable breath test or chemical test under Indiana's Implied Consent Law and did not even seek Wiggins' consent before ordering the urine test.

12004–2004

Statutes the citing opinions construe

IN § Ind. Code § 9-30-7-3 (5) IN § Ind. Code § 9-30-5-5 (4) IN § Ind. Code § 9-30-5-4 (3) IN § Ind. Code § 9-30-6-6 (3)

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

OH 24 (2002–2020) TX 15 (2005–2019) NY 13 (2012–2025) MO 11 (2000–2023) IN 11 (2003–2026) WA 6 (1995–2024) AR 4 (1994–2014) MN 3 (2003–2019) NM 3 (2011–2014) MS 3 (2003–2012) SD 2 (1985–2005) PA 2 (2014–2019) GA 2 (2022–2023) MT 2 (2002–2004) NC 2 (2014–2014)

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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