HGN test (Kansas) · Go Syfert
← Kansas issues

HGN test in Kansas

11 Kansas opinions name it 2 courts 1992–2022 2 in the last five years

The cases below were cited by Kansas 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 (20)

CaseFollowedCited
State v. Rosegreen
moctapp · 2002 · cited in 2 Kansas opinions naming this issue, 2009–2010
2 sentences

2010App. 543, 553 , 723 A.2d 494 (1999) (permitting testimony regarding HGN test results but finding error when testimony included an opinion of defendant’s BAC); State v. Rose, 86 S.W.3d 90, 100 (Mo. App. 2002) (allowing evidence of HGN test results as circumstantial evidence of intoxication but not as evidence of specific BAC); State v. Baue, 258 Neb. 968, 985-87 , 607 N.W.2d 191 (2000) (same); State v. Dahood, 148 N.H. 723, 734 , 814 A.2d 159 (2002) (same); Brewer v. Ziegler, 743 N.W.2d 391, 400 (N.D. 2007) (same); State v. Sullivan, 310 S.C. 311, 315-16 , 426 S.E.2d 766 (1993) (same); Emerson

2009App. 543, 553 , 723 A.2d 494 (1999) (permitting testimony regarding HGN test results but finding error when testimony included an opinion that Wilson was at or above .10 BAC); State v. Rose, 86 S.W.3d 90, 100 (Mo. App. 2002) (allowing evidence of HGN test results as circumstantial evidence of intoxication but not as evidence of a specific BAC level); State v. Baue, 258 Neb. 968, 985-87 , 607 N.W.2d 191 (2000) (same); State v. Dahood, 148 N.H. 723, 734 , 814 A.2d 159 (2002) (same); Brewer v. Ziegler, 743 N.W.2d 391, 400 (N.D. 2007) (admitting evidence of HGN test results as circumstantial evide

22
Brewer v. Zieglergreen
nd · 2007 · cited in 2 Kansas opinions naming this issue, 2009–2010
2 sentences

2010App. 543, 553 , 723 A.2d 494 (1999) (permitting testimony regarding HGN test results but finding error when testimony included an opinion of defendant’s BAC); State v. Rose, 86 S.W.3d 90, 100 (Mo. App. 2002) (allowing evidence of HGN test results as circumstantial evidence of intoxication but not as evidence of specific BAC); State v. Baue, 258 Neb. 968, 985-87 , 607 N.W.2d 191 (2000) (same); State v. Dahood, 148 N.H. 723, 734 , 814 A.2d 159 (2002) (same); Brewer v. Ziegler, 743 N.W.2d 391, 400 (N.D. 2007) (same); State v. Sullivan, 310 S.C. 311, 315-16 , 426 S.E.2d 766 (1993) (same); Emerson

2009App. 543, 553 , 723 A.2d 494 (1999) (permitting testimony regarding HGN test results but finding error when testimony included an opinion that Wilson was at or above .10 BAC); State v. Rose, 86 S.W.3d 90, 100 (Mo. App. 2002) (allowing evidence of HGN test results as circumstantial evidence of intoxication but not as evidence of a specific BAC level); State v. Baue, 258 Neb. 968, 985-87 , 607 N.W.2d 191 (2000) (same); State v. Dahood, 148 N.H. 723, 734 , 814 A.2d 159 (2002) (same); Brewer v. Ziegler, 743 N.W.2d 391, 400 (N.D. 2007) (admitting evidence of HGN test results as circumstantial evide

22
Emerson v. Stategreen
texcrimapp · 1994 · cited in 2 Kansas opinions naming this issue, 2009–2010
2 sentences

2010App. 543, 553 , 723 A.2d 494 (1999) (permitting testimony regarding HGN test results but finding error when testimony included an opinion of defendant’s BAC); State v. Rose, 86 S.W.3d 90, 100 (Mo. App. 2002) (allowing evidence of HGN test results as circumstantial evidence of intoxication but not as evidence of specific BAC); State v. Baue, 258 Neb. 968, 985-87 , 607 N.W.2d 191 (2000) (same); State v. Dahood, 148 N.H. 723, 734 , 814 A.2d 159 (2002) (same); Brewer v. Ziegler, 743 N.W.2d 391, 400 (N.D. 2007) (same); State v. Sullivan, 310 S.C. 311, 315-16 , 426 S.E.2d 766 (1993) (same); Emerson

2009App. 543, 553 , 723 A.2d 494 (1999) (permitting testimony regarding HGN test results but finding error when testimony included an opinion that Wilson was at or above .10 BAC); State v. Rose, 86 S.W.3d 90, 100 (Mo. App. 2002) (allowing evidence of HGN test results as circumstantial evidence of intoxication but not as evidence of a specific BAC level); State v. Baue, 258 Neb. 968, 985-87 , 607 N.W.2d 191 (2000) (same); State v. Dahood, 148 N.H. 723, 734 , 814 A.2d 159 (2002) (same); Brewer v. Ziegler, 743 N.W.2d 391, 400 (N.D. 2007) (admitting evidence of HGN test results as circumstantial evide

22
Ballard v. Stategreen
alaskactapp · 1998 · cited in 2 Kansas opinions naming this issue, 2009–2010
2 sentences

2010See, e.g., Ballard v. State, 955 P.2d 931, 940 (Alaska App. 1998), overruled on other grounds by State v. Coon, 974 P.2d 386 (Alaska 1999) (concluding that HGN test results are admissible as circumstantial evidence of intoxication but inadmissible to establish a particular BAC); State v. Campoy, 214 Ariz. 132, 134-35 , 149 P.3d 756 (Ct. App. 2006) (same); People v. *824 Rose, 268 Ill.

2009See, e.g., Ballard v. State, 955 P.2d 931, 940 (Alaska App. 1998), overruled on other grounds State v. Coon, 974 P.2d 386 (Alaska 1999) (concluding that HGN test results are admissible as circumstantial evidence of intoxication but inadmissible to establish a particular blood-alcohol concentration [BAC] level); State v. Campoy, 214 Ariz. 132, n134-35 , 149 P.3d 756 (Ariz. App. 2006) (same); People v. Rose, 268 Ill.

22
Schmidt v. Stategreen
indctapp · 2004 · cited in 2 Kansas opinions naming this issue, 2009–2010
2 sentences

2010App. 3d 174, 181 , 643 N.E.2d 865 (1994) (distinguishing between the admission of field sobriety test results and preliminary breath test results because the breath test registered body chemistry rather than recording behavioral characteristics); Schmidt v. State, 816 N.E.2d 925, 946 (Ind. App. 2004) (suggesting that admission of evidence regarding statistical probability that an individual who failed a field sobriety test would have a BAC over .10 is improper in the State’s case-in-chief); State v. Murphy, 451 N.W.2d 154, 157-58 (Iowa 1990) (quoting a statement from State v. Nagel, 30 Ohio Ap

2009App. 3d 174, 181 , 643 N.E.2d 865 (1994) (distinguishing between the admission of field sobriety test results and preliminary breath test results because the breath test registered body chemistry rather than recording behavioral characteristics); Schmidt v. State, 816 N.E.2d 925, 946 (Ind. App. 2004) (suggesting that admission of evidence regarding statistical probability that an individual who failed a field sobriety test would have a BAC over .10 is improper in the State’s case-in-chief); Wilson v. State, 124 Md.

22
State v. Coongreen
alaska · 1999 · cited in 2 Kansas opinions naming this issue, 2009–2010
2 sentences

2010See, e.g., Ballard v. State, 955 P.2d 931, 940 (Alaska App. 1998), overruled on other grounds by State v. Coon, 974 P.2d 386 (Alaska 1999) (concluding that HGN test results are admissible as circumstantial evidence of intoxication but inadmissible to establish a particular BAC); State v. Campoy, 214 Ariz. 132, 134-35 , 149 P.3d 756 (Ct. App. 2006) (same); People v. *824 Rose, 268 Ill.

2009See, e.g., Ballard v. State, 955 P.2d 931, 940 (Alaska App. 1998), overruled on other grounds State v. Coon, 974 P.2d 386 (Alaska 1999) (concluding that HGN test results are admissible as circumstantial evidence of intoxication but inadmissible to establish a particular blood-alcohol concentration [BAC] level); State v. Campoy, 214 Ariz. 132, n134-35 , 149 P.3d 756 (Ariz. App. 2006) (same); People v. Rose, 268 Ill.

22
City of Wichita v. Molitorgreen
kan · 2015 · cited in 5 Kansas opinions naming this issue, 2018–2022
2 sentences

2022ANALYSIS THE INCLUSION OF THE HGN TEST RESULTS IN THE PROBABLE CAUSE AFFIDAVIT DID NOT RENDER THE WARRANT TO DRAW FULLMER'S BLOOD INVALID On appeal, Fullmer revives his argument that the warrant authorizing his blood draw was invalid because it rested in part on his failed HGN test—the results of which are unreliable under City of Wichita v. Molitor, 301 Kan. 251, 264 , 341 P.3d 1275 (2015).

2022ANALYSIS THE INCLUSION OF THE HGN TEST RESULTS IN THE PROBABLE CAUSE AFFIDAVIT DID NOT RENDER THE WARRANT TO DRAW FULLMER'S BLOOD INVALID On appeal, Fullmer revives his argument that the warrant authorizing his blood draw was invalid because it rested in part on his failed HGN test—the results of which are unreliable under City of Wichita v. Molitor, 301 Kan. 251, 264 , 341 P.3d 1275 (2015).

15
Frye v. United Statesred
cadc · 1923 · cited in 2 Kansas opinions naming this issue, 1992–2015
2 sentences

2015He claims that the test for reliability set forth in Frye v. United States, 293 F. 1013 (D.C.

2015He claims that the test for reliability set forth in Frye v. United States, 293 F. 1013 (D.C.

12
State v. Nagelgreen
ohioctapp · 1986 · cited in 2 Kansas opinions naming this issue, 1992–2010
2 sentences

2010App. 3d 174, 181 , 643 N.E.2d 865 (1994) (distinguishing between the admission of field sobriety test results and preliminary breath test results because the breath test registered body chemistry rather than recording behavioral characteristics); Schmidt v. State, 816 N.E.2d 925, 946 (Ind. App. 2004) (suggesting that admission of evidence regarding statistical probability that an individual who failed a field sobriety test would have a BAC over .10 is improper in the State’s case-in-chief); State v. Murphy, 451 N.W.2d 154, 157-58 (Iowa 1990) (quoting a statement from State v. Nagel, 30 Ohio Ap

2010App. 3d 174, 181 , 643 N.E.2d 865 (1994) (distinguishing between the admission of field sobriety test results and preliminary breath test results because the breath test registered body chemistry rather than recording behavioral characteristics); Schmidt v. State, 816 N.E.2d 925, 946 (Ind. App. 2004) (suggesting that admission of evidence regarding statistical probability that an individual who failed a field sobriety test would have a BAC over .10 is improper in the State’s case-in-chief); State v. Murphy, 451 N.W.2d 154, 157-58 (Iowa 1990) (quoting a statement from State v. Nagel, 30 Ohio Ap

12
State v. Sullivangreen
sc · 1993 · cited in 2 Kansas opinions naming this issue, 2009–2010
2 sentences

2010App. 543, 553 , 723 A.2d 494 (1999) (permitting testimony regarding HGN test results but finding error when testimony included an opinion of defendant’s BAC); State v. Rose, 86 S.W.3d 90, 100 (Mo. App. 2002) (allowing evidence of HGN test results as circumstantial evidence of intoxication but not as evidence of specific BAC); State v. Baue, 258 Neb. 968, 985-87 , 607 N.W.2d 191 (2000) (same); State v. Dahood, 148 N.H. 723, 734 , 814 A.2d 159 (2002) (same); Brewer v. Ziegler, 743 N.W.2d 391, 400 (N.D. 2007) (same); State v. Sullivan, 310 S.C. 311, 315-16 , 426 S.E.2d 766 (1993) (same); Emerson

2010App. 543, 553 , 723 A.2d 494 (1999) (permitting testimony regarding HGN test results but finding error when testimony included an opinion of defendant’s BAC); State v. Rose, 86 S.W.3d 90, 100 (Mo. App. 2002) (allowing evidence of HGN test results as circumstantial evidence of intoxication but not as evidence of specific BAC); State v. Baue, 258 Neb. 968, 985-87 , 607 N.W.2d 191 (2000) (same); State v. Dahood, 148 N.H. 723, 734 , 814 A.2d 159 (2002) (same); Brewer v. Ziegler, 743 N.W.2d 391, 400 (N.D. 2007) (same); State v. Sullivan, 310 S.C. 311, 315-16 , 426 S.E.2d 766 (1993) (same); Emerson

12
Law v. Law Co. Building Associatesgreen
kan · 2012 · cited in 1 Kansas opinions naming this issue, 2015–2015
2 sentences

2015See Black’s Law Dictionary 549 (10th ed. 2014) (judicial dictum is opinion “that is not essential to the decision”); see also Law v. Law Company Building Assocs., 295 Kan. 551, 564 , 289 P.3d 1066 (2012) (“ ‘Nobody is bound by dictum . . . .’ ”).

2015See Black’s Law Dictionary 549 (10th ed. 2014) (judicial dictum is opinion “that is not essential to the decision”); see also Law v. Law Company Building Assocs., 295 Kan. 551, 564 , 289 P.3d 1066 (2012) (“ ‘Nobody is bound by dictum . . . .’ ”).

11
State v. Pollmangreen
kan · 2008 · cited in 1 Kansas opinions naming this issue, 2012–2012
2 sentences

2012See State v. Tollman, 286 Kan. 881 , Syl. ¶ 7, 190 P.3d 234 (2008) (failure to follow officer’s directions, smell of alcohol, and admission of drinking provided reasonable suspicion sufficient to justify officer’s request for PBT).

2012See State v. Tollman, 286 Kan. 881 , Syl. ¶ 7, 190 P.3d 234 (2008) (failure to follow officer’s directions, smell of alcohol, and admission of drinking provided reasonable suspicion sufficient to justify officer’s request for PBT).

11
Strickland v. City of Dothan, ALgreen
almd · 2005 · cited in 1 Kansas opinions naming this issue, 2012–2012
1 sentence

2012See Strickland v. City of Dothan, AL, 399 F. Supp. 2d 1275 , 1288 n.29 (M.D.

11
State v. Murphygreen
iowa · 1990 · cited in 1 Kansas opinions naming this issue, 2010–2010
1 sentence

2010App. 3d 174, 181 , 643 N.E.2d 865 (1994) (distinguishing between the admission of field sobriety test results and preliminary breath test results because the breath test registered body chemistry rather than recording behavioral characteristics); Schmidt v. State, 816 N.E.2d 925, 946 (Ind. App. 2004) (suggesting that admission of evidence regarding statistical probability that an individual who failed a field sobriety test would have a BAC over .10 is improper in the State’s case-in-chief); State v. Murphy, 451 N.W.2d 154, 157-58 (Iowa 1990) (quoting a statement from State v. Nagel, 30 Ohio Ap

11
Plouff v. Stategreen
texapp · 2006 · cited in 1 Kansas opinions naming this issue, 2010–2010
11
State v. Murphygreen
tenn · 1997 · cited in 1 Kansas opinions naming this issue, 2010–2010
11
State v. Armstronggreen
lactapp · 1990 · cited in 1 Kansas opinions naming this issue, 1992–1992
11
Angle v. Kansas Department of Revenuegreen
kanctapp · 1988 · cited in 1 Kansas opinions naming this issue, 1992–1992
11
State v. McNaughtgreen
kan · 1986 · cited in 1 Kansas opinions naming this issue, 1992–1992
11
State v. Bressongreen
ohio · 1990 · cited in 1 Kansas opinions naming this issue, 1992–1992
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (33)

CaseCitedYears
State v. Witte green
kan · 1992
2 sentences

2015The opinion noted that NHTSA claimed that “the HGN test is an accurate and effective field sobriety test to determine whether a drivers alcohol concentration is above .10.” 251 Kan. at 315 .

2015The opinion noted that NHTSA claimed that “the HGN test is an accurate and effective field sobriety test to determine whether a drivers alcohol concentration is above .10.” 251 Kan. at 315 .

52006–2015
State v. Chastain green
kan · 1998
2 sentences

2010Six years later, in Chastain, 265 Kan. 16 , this court was asked to reexamine Witte in light of subsequent decisions in four states that allowed the use of the HGN test.

2010Six years later, in Chastain, 265 Kan. 16 , this court was asked to reexamine Witte in light of subsequent decisions in four states that allowed the use of the HGN test.

22010–2015
Wilson v. State green
mdctspecapp · 1999
2 sentences

2010App. 543, 553 , 723 A.2d 494 (1999) (permitting testimony regarding HGN test results but finding error when testimony included an opinion of defendant’s BAC); State v. Rose, 86 S.W.3d 90, 100 (Mo. App. 2002) (allowing evidence of HGN test results as circumstantial evidence of intoxication but not as evidence of specific BAC); State v. Baue, 258 Neb. 968, 985-87 , 607 N.W.2d 191 (2000) (same); State v. Dahood, 148 N.H. 723, 734 , 814 A.2d 159 (2002) (same); Brewer v. Ziegler, 743 N.W.2d 391, 400 (N.D. 2007) (same); State v. Sullivan, 310 S.C. 311, 315-16 , 426 S.E.2d 766 (1993) (same); Emerson

2009App. 543, 553 , 723 A.2d 494 (1999) (permitting testimony regarding HGN test results but finding error when testimony included an opinion that Wilson was at or above .10 BAC); State v. Rose, 86 S.W.3d 90, 100 (Mo. App. 2002) (allowing evidence of HGN test results as circumstantial evidence of intoxication but not as evidence of a specific BAC level); State v. Baue, 258 Neb. 968, 985-87 , 607 N.W.2d 191 (2000) (same); State v. Dahood, 148 N.H. 723, 734 , 814 A.2d 159 (2002) (same); Brewer v. Ziegler, 743 N.W.2d 391, 400 (N.D. 2007) (admitting evidence of HGN test results as circumstantial evide

22009–2010
State v. Campoy green
arizctapp · 2006
2 sentences

2010See, e.g., Ballard v. State, 955 P.2d 931, 940 (Alaska App. 1998), overruled on other grounds by State v. Coon, 974 P.2d 386 (Alaska 1999) (concluding that HGN test results are admissible as circumstantial evidence of intoxication but inadmissible to establish a particular BAC); State v. Campoy, 214 Ariz. 132, 134-35 , 149 P.3d 756 (Ct. App. 2006) (same); People v. *824 Rose, 268 Ill.

2010See, e.g., Ballard v. State, 955 P.2d 931, 940 (Alaska App. 1998), overruled on other grounds by State v. Coon, 974 P.2d 386 (Alaska 1999) (concluding that HGN test results are admissible as circumstantial evidence of intoxication but inadmissible to establish a particular BAC); State v. Campoy, 214 Ariz. 132, 134-35 , 149 P.3d 756 (Ct. App. 2006) (same); People v. *824 Rose, 268 Ill.

22009–2010
State v. Dahood green
nh · 2002
2 sentences

2010App. 543, 553 , 723 A.2d 494 (1999) (permitting testimony regarding HGN test results but finding error when testimony included an opinion of defendant’s BAC); State v. Rose, 86 S.W.3d 90, 100 (Mo. App. 2002) (allowing evidence of HGN test results as circumstantial evidence of intoxication but not as evidence of specific BAC); State v. Baue, 258 Neb. 968, 985-87 , 607 N.W.2d 191 (2000) (same); State v. Dahood, 148 N.H. 723, 734 , 814 A.2d 159 (2002) (same); Brewer v. Ziegler, 743 N.W.2d 391, 400 (N.D. 2007) (same); State v. Sullivan, 310 S.C. 311, 315-16 , 426 S.E.2d 766 (1993) (same); Emerson

2010App. 543, 553 , 723 A.2d 494 (1999) (permitting testimony regarding HGN test results but finding error when testimony included an opinion of defendant’s BAC); State v. Rose, 86 S.W.3d 90, 100 (Mo. App. 2002) (allowing evidence of HGN test results as circumstantial evidence of intoxication but not as evidence of specific BAC); State v. Baue, 258 Neb. 968, 985-87 , 607 N.W.2d 191 (2000) (same); State v. Dahood, 148 N.H. 723, 734 , 814 A.2d 159 (2002) (same); Brewer v. Ziegler, 743 N.W.2d 391, 400 (N.D. 2007) (same); State v. Sullivan, 310 S.C. 311, 315-16 , 426 S.E.2d 766 (1993) (same); Emerson

22009–2010
People v. Rose green
illappct · 1994
2 sentences

2010See, e.g., Ballard v. State, 955 P.2d 931, 940 (Alaska App. 1998), overruled on other grounds by State v. Coon, 974 P.2d 386 (Alaska 1999) (concluding that HGN test results are admissible as circumstantial evidence of intoxication but inadmissible to establish a particular BAC); State v. Campoy, 214 Ariz. 132, 134-35 , 149 P.3d 756 (Ct. App. 2006) (same); People v. *824 Rose, 268 Ill.

2009See, e.g., Ballard v. State, 955 P.2d 931, 940 (Alaska App. 1998), overruled on other grounds State v. Coon, 974 P.2d 386 (Alaska 1999) (concluding that HGN test results are admissible as circumstantial evidence of intoxication but inadmissible to establish a particular blood-alcohol concentration [BAC] level); State v. Campoy, 214 Ariz. 132, n134-35 , 149 P.3d 756 (Ariz. App. 2006) (same); People v. Rose, 268 Ill.

22009–2010
State v. Superior Court green
ariz · 1986
2 sentences

2010App. 1997) (explaining that the battery of field sobriety tests typically includes the one-leg-stand test, the walk-and-tum test, and the finger-to-nose test, are designed to disclose “physical manifestations of intoxication,” and do not “require the evidentiary foundation for the admission of expert scientific testimony”); State v. Superior Court, 149 Ariz. 269, 276 , 718 P.2d 171 (1986) (distinguishing the horizontal gaze nystagmus [HGN] test, which rests upon an assertion of scientific legitimacy, from the *821 psychomotor tests, which rely upon a basis of common knowledge, and holding that

2010App. 1997) (explaining that the battery of field sobriety tests typically includes the one-leg-stand test, the walk-and-tum test, and the finger-to-nose test, are designed to disclose “physical manifestations of intoxication,” and do not “require the evidentiary foundation for the admission of expert scientific testimony”); State v. Superior Court, 149 Ariz. 269, 276 , 718 P.2d 171 (1986) (distinguishing the horizontal gaze nystagmus [HGN] test, which rests upon an assertion of scientific legitimacy, from the *821 psychomotor tests, which rely upon a basis of common knowledge, and holding that

21992–2010
People v. Williams green
calctapp · 1992
2 sentences

2010App. 1997) (explaining that the battery of field sobriety tests typically includes the one-leg-stand test, the walk-and-tum test, and the finger-to-nose test, are designed to disclose “physical manifestations of intoxication,” and do not “require the evidentiary foundation for the admission of expert scientific testimony”); State v. Superior Court, 149 Ariz. 269, 276 , 718 P.2d 171 (1986) (distinguishing the horizontal gaze nystagmus [HGN] test, which rests upon an assertion of scientific legitimacy, from the *821 psychomotor tests, which rely upon a basis of common knowledge, and holding that

2010App. 1997) (explaining that the battery of field sobriety tests typically includes the one-leg-stand test, the walk-and-tum test, and the finger-to-nose test, are designed to disclose “physical manifestations of intoxication,” and do not “require the evidentiary foundation for the admission of expert scientific testimony”); State v. Superior Court, 149 Ariz. 269, 276 , 718 P.2d 171 (1986) (distinguishing the horizontal gaze nystagmus [HGN] test, which rests upon an assertion of scientific legitimacy, from the *821 psychomotor tests, which rely upon a basis of common knowledge, and holding that

21992–2010
Mount v. El Dorado County Superior Court green
scotus · 1994
2 sentences

2010App. 543, 553 , 723 A.2d 494 (1999) (permitting testimony regarding HGN test results but finding error when testimony included an opinion of defendant’s BAC); State v. Rose, 86 S.W.3d 90, 100 (Mo. App. 2002) (allowing evidence of HGN test results as circumstantial evidence of intoxication but not as evidence of specific BAC); State v. Baue, 258 Neb. 968, 985-87 , 607 N.W.2d 191 (2000) (same); State v. Dahood, 148 N.H. 723, 734 , 814 A.2d 159 (2002) (same); Brewer v. Ziegler, 743 N.W.2d 391, 400 (N.D. 2007) (same); State v. Sullivan, 310 S.C. 311, 315-16 , 426 S.E.2d 766 (1993) (same); Emerson

2009App. 543, 553 , 723 A.2d 494 (1999) (permitting testimony regarding HGN test results but finding error when testimony included an opinion that Wilson was at or above .10 BAC); State v. Rose, 86 S.W.3d 90, 100 (Mo. App. 2002) (allowing evidence of HGN test results as circumstantial evidence of intoxication but not as evidence of a specific BAC level); State v. Baue, 258 Neb. 968, 985-87 , 607 N.W.2d 191 (2000) (same); State v. Dahood, 148 N.H. 723, 734 , 814 A.2d 159 (2002) (same); Brewer v. Ziegler, 743 N.W.2d 391, 400 (N.D. 2007) (admitting evidence of HGN test results as circumstantial evide

22009–2010
State v. Baue green
neb · 2000
2 sentences

2010App. 543, 553 , 723 A.2d 494 (1999) (permitting testimony regarding HGN test results but finding error when testimony included an opinion of defendant’s BAC); State v. Rose, 86 S.W.3d 90, 100 (Mo. App. 2002) (allowing evidence of HGN test results as circumstantial evidence of intoxication but not as evidence of specific BAC); State v. Baue, 258 Neb. 968, 985-87 , 607 N.W.2d 191 (2000) (same); State v. Dahood, 148 N.H. 723, 734 , 814 A.2d 159 (2002) (same); Brewer v. Ziegler, 743 N.W.2d 391, 400 (N.D. 2007) (same); State v. Sullivan, 310 S.C. 311, 315-16 , 426 S.E.2d 766 (1993) (same); Emerson

2010App. 543, 553 , 723 A.2d 494 (1999) (permitting testimony regarding HGN test results but finding error when testimony included an opinion of defendant’s BAC); State v. Rose, 86 S.W.3d 90, 100 (Mo. App. 2002) (allowing evidence of HGN test results as circumstantial evidence of intoxication but not as evidence of specific BAC); State v. Baue, 258 Neb. 968, 985-87 , 607 N.W.2d 191 (2000) (same); State v. Dahood, 148 N.H. 723, 734 , 814 A.2d 159 (2002) (same); Brewer v. Ziegler, 743 N.W.2d 391, 400 (N.D. 2007) (same); State v. Sullivan, 310 S.C. 311, 315-16 , 426 S.E.2d 766 (1993) (same); Emerson

22009–2010
State v. Henry green
kan · 1997
2 sentences

2022For its part, the State directs our attention to State v. Henry, 263 Kan. 118, 128 , 947 P.2d 1020 (1997).

2022For its part, the State directs our attention to State v. Henry, 263 Kan. 118, 128 , 947 P.2d 1020 (1997).

12022–2022
Franks v. Delaware green
scotus · 1978
2 sentences

2022The State argues the Molitor rule does not apply to search warrant applications. 3 In Franks v. Delaware, 438 U.S. 154 , 98 S. Ct. 2674 , 57 L.

2022The State argues the Molitor rule does not apply to search warrant applications. 3 In Franks v. Delaware, 438 U.S. 154 , 98 S. Ct. 2674 , 57 L.

12022–2022
Sloop v. Kansas Department of Revenue green
kan · 2012
2 sentences

2020As in other totality of the circumstances tests, there is no rigid application of factors and courts should not merely count the facts or factors that support one side of the determination or the other.' [Citations omitted.]" 296 Kan. at 20 . 6 We begin by asking whether the district court's decision to suppress the HGN test result and the request for a PBT were supported by our Supreme Court's decision in Molitor.

2020As in other totality of the circumstances tests, there is no rigid application of factors and courts should not merely count the facts or factors that support one side of the determination or the other.' [Citations omitted.]" 296 Kan. at 20 . 6 We begin by asking whether the district court's decision to suppress the HGN test result and the request for a PBT were supported by our Supreme Court's decision in Molitor.

12020–2020
City of Wichita v. Molitor green
kanctapp · 2012
2 sentences

2015The panel found that while there was still considerable debate throughout other jurisdictions as to whether HGN test results could be admissible at trial, it was unable to find any authority from other jurisdictions holding that HGN test results could not be considered for the purposes of determining probable cause in a DUI case. 46 Kan.

2015The panel concluded that because reasonable suspicion is a less demanding standard than probable cause, “HGN test results may, under appropriate circumstances, be considered as part of the totality of the circumstances in determining whether a law enforcement officer has reasonable suspicion to request a PBT.” 46 Kan.

12015–2015
State v. McClanahan green
kan · 1973
2 sentences

2015Cf. State v. McClanahan, 212 Kan. 208, 211 , 510 P.2d 153 (1973) (competency of evidence is question of law).

2015Cf. State v. McClanahan, 212 Kan. 208, 211 , 510 P.2d 153 (1973) (competency of evidence is question of law).

12015–2015
State v. Shadden green
kan · 2010
1 sentence

2012In support of this finding, the Kansas Supreme Court cited several cases from other jurisdictions — including Alaska, Maryland, Missouri, Nebraska, New Hampshire, North Dakota, South Carolina, and Texas — in which it was held that HGN test results are admissible as circumstantial evidence of intoxication but inadmissible to establish a specific BAC. 290 Kan. at 823-24 .

12012–2012
City of New York v. Allied Outdoor Advertising, Inc. green
nysupct · 1997
12010–2010
People v. DiNonno green
nyappterm · 1997
12010–2010
Hawkins v. State green
gactapp · 1996
12010–2010
State v. Carson green
mo · 1997
12009–2009
State v. Meador green
fladistctapp · 1996
12009–2009
State v. Hill green
moctapp · 1993
12009–2009
People v. Dakuras green
illappct · 1988
11992–1992
People v. Sides green
illappct · 1990
11992–1992
State v. Garrett green
idaho · 1991
11992–1992
State v. Clark green
mont · 1988
11992–1992
People v. Jebelian neutral
illappct · 1990
11992–1992
Commonwealth v. Miller green
pa · 1987
11992–1992
State v. Kelly green
kanctapp · 1990
11992–1992
State Ex Rel. Hamilton v. City Court of City of Mesa green
ariz · 1990
11992–1992
State v. Maze green
kanctapp · 1992
11992–1992
Smith v. Deppish green
kan · 1991
11992–1992
Malone v. City of Silverhill green
ala · 1990
11992–1992

Statutes the citing opinions construe

KS § K.S.A. § 8-1567 (4) KS § K.S.A. § 60-401 (3) KS § K.S.A. § 60-456 (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

TX 309 (1987–2026) OH 179 (1990–2026) IL 96 (1988–2026) GA 70 (1992–2025) OR 57 (1987–2026) NM 34 (1998–2024) MO 31 (1993–2024) PA 27 (1987–2024) AZ 21 (1985–2016) NC 20 (1997–2025) MT 19 (1988–2025) HI 18 (1999–2023) ME 17 (1997–2022) MS 17 (1994–2023) TN 16 (1997–2025) DE 15 (1996–2026) WA 15 (1994–2025) AL 14 (1989–2018) NY 14 (1991–2019) WI 13 (1999–2024) ID 13 (1991–2024) FL 13 (1987–2012) CA 13 (1990–2024) SC 12 (1996–2017) KS 11 (1992–2022) ND 10 (1994–2023) WV 10 (1988–2019) NH 9 (2002–2019) MD 9 (1995–2024) CT 8 (1994–2002) VT 8 (1998–2022) NJ 6 (2000–2020) MA 6 (1997–2026) LA 6 (1990–2012) IA 6 (1990–2019) DC 6 (2001–2024) IN 5 (2003–2018) NE 4 (2000–2026) MI 4 (1996–2024) AR 4 (1993–2025) KY 4 (1996–2025) CO 4 (2019–2025) UT 4 (1995–2025) AK 3 (1990–1998) VA 2 (2012–2024) OK 2 (2010–2020) SD 2 (2002–2013)

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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