Intoxilyzer test (Colorado) · Go Syfert
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Intoxilyzer test in Colorado

10 Colorado opinions name it 2 courts 1984–2002 0 in the last five years

The cases below were cited by Colorado 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 (2)

CaseFollowedCited
Brewer v. Motor Vehicle Division, Department of Revenuegreen
colo · 1986 · cited in 3 Colorado opinions naming this issue, 1988–1995
2 sentences

1995In McBroom , we interpreted Bowers to signify that a breath test is to “be administered in accordance with health department rules and regulations” and that, “ ‘if there was a deficiency in the evidence of compliance with board of health regulations, ... the intoxilyzer test results are not automatically inadmissible.’ ” Id. at 242 (quoting Brewer v. Motor Vehicle Division, 720 P.2d 564, 568 (Colo.1986)).

1988However, we also held in Brewer that “[e]ven if there was a deficiency in the evidence of compliance with board of health regulations, a question we do not decide, the intoxilyzer test results are not automatically inadmissible.” Id. (emphasis added). 4 *242 We came to the same conclusion in People v. Bowers, 716 P.2d 471 (Colo.1986), where we addressed the admissibility of BAC test results as evidence in a criminal trial, rather than in a revocation hearing.

13
People v. Bowersgreen
colo · 1986 · cited in 3 Colorado opinions naming this issue, 1986–1988
2 sentences

1988In People v. Bowers, 716 P.2d 471 (Colo.1986), this court held that intoxilyzer test results were admissible into evidence if the trial court was satisfied that the breath test was scientifically valid and reliable and was conducted by a qualified person using properly working testing devices.

1988However, we also held in Brewer that “[e]ven if there was a deficiency in the evidence of compliance with board of health regulations, a question we do not decide, the intoxilyzer test results are not automatically inadmissible.” Id. (emphasis added). 4 *242 We came to the same conclusion in People v. Bowers, 716 P.2d 471 (Colo.1986), where we addressed the admissibility of BAC test results as evidence in a criminal trial, rather than in a revocation hearing.

13

Distinguished, questioned or overruled (0)

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

Also cited on this issue (8)

CaseCitedYears
Aultman v. Motor Vehicle Division, Department of Revenue green
coloctapp · 1985
2 sentences

1987Schocke v. State, supra; Aultman v. Motor Vehicle Division, 706 P.2d 5 (Colo.App.1985).

1986Aultman v. Motor Vehicle Division, 706 P.2d 5 (Colo.App. 1985).

31986–1987
Charnes v. Robinson green
colo · 1989
1 sentence

2002However, under § 424-1301(2)(b), C.R.8.2001, a licensee is entitled to "offer direct and cireurastantial evidence to show that there is a disparity between what the tests show and other facts so that the trier of fact could infer that the tests were in some way defective or inaccurate." See Charnes v. Robinson, supra, 772 P.2d at 67 (quoting identical text from predecessor statute).

12002–2002
Colorado Department of Revenue v. McBroom green
colo · 1988
1 sentence

1995In McBroom , we interpreted Bowers to signify that a breath test is to “be administered in accordance with health department rules and regulations” and that, “ ‘if there was a deficiency in the evidence of compliance with board of health regulations, ... the intoxilyzer test results are not automatically inadmissible.’ ” Id. at 242 (quoting Brewer v. Motor Vehicle Division, 720 P.2d 564, 568 (Colo.1986)).

11995–1995
Schocke v. ST., DEPT. OF REV., MOTOR VEH. DIV. green
coloctapp · 1986
2 sentences

1987Schocke v. State, supra. Intoxilyzer test results are presumed accurate if the test was conducted by a certified operator in accordance with Health Department regulations on a machine shown to be operating correctly at the time of the test.

1987Schocke v. State, supra; Aultman v. Motor Vehicle Division, 706 P.2d 5 (Colo.App.1985).

11987–1987
California v. Trombetta green
scotus · 1984
1 sentence

1985Because the testing of a breath sample by the defendant would probably simply confirm the results of the state’s intoxilyzer test, and because the defendant could have demonstrated any lack of reliability of that test by a number of other means, the court concluded that “the Due Process Clause of the Fourteenth Amendment does not require that law enforcement agencies preserve breath samples in order to introduce breath-analysis tests at trial.” 10 104 S.Ct. at 2535 .

11985–1985
People v. Aragon green
colo · 1974
2 sentences

1984Ramirez v. People, 682 P.2d 1181 (Colo.1984); People v. Aragon, 186 Colo. 91 , 525 P.2d 1134 (1974); People v. Barker, 180 Colo. 28 , 501 P.2d 1041 (1972).

1984Ramirez v. People, 682 P.2d 1181 (Colo.1984); People v. Aragon, 186 Colo. 91 , 525 P.2d 1134 (1974); People v. Barker, 180 Colo. 28 , 501 P.2d 1041 (1972).

11984–1984
People v. Barker green
colo · 1972
2 sentences

1984Ramirez v. People, 682 P.2d 1181 (Colo.1984); People v. Aragon, 186 Colo. 91 , 525 P.2d 1134 (1974); People v. Barker, 180 Colo. 28 , 501 P.2d 1041 (1972).

1984Ramirez v. People, 682 P.2d 1181 (Colo.1984); People v. Aragon, 186 Colo. 91 , 525 P.2d 1134 (1974); People v. Barker, 180 Colo. 28 , 501 P.2d 1041 (1972).

11984–1984
Ramirez v. People green
colo · 1984
1 sentence

1984Ramirez v. People, 682 P.2d 1181 (Colo.1984); People v. Aragon, 186 Colo. 91 , 525 P.2d 1134 (1974); People v. Barker, 180 Colo. 28 , 501 P.2d 1041 (1972).

11984–1984

Statutes the citing opinions construe

CO § Colo. Rev. Stat. § 42-4-1202 (6)

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 103 (1985–2021) ND 90 (1985–2025) OR 34 (1981–2025) HI 32 (1985–2021) MN 31 (1986–2019) MS 24 (1992–2021) OH 22 (1980–2024) NC 18 (1999–2024) ME 16 (1983–2020) DE 15 (1996–2025) GA 14 (1998–2016) AZ 14 (1982–2003) PA 12 (1986–2023) NY 11 (1991–2024) NE 10 (1987–2020) CO 10 (1984–2002) KS 9 (1998–2021) LA 9 (1996–2008) UT 8 (1988–2019) IN 7 (1986–2004) AL 6 (1988–1997) CA 5 (1985–2014) IL 5 (1984–2010) IA 5 (1996–2016) SD 3 (1994–2009) WI 3 (1994–2019)

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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