urine test (North Dakota) · Go Syfert
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urine test in North Dakota

8 North Dakota opinions name it 1 courts 2005–2025 4 in the last five years

The cases below were cited by North Dakota 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
Bosch v. Mooregreen
nd · 1994 · cited in 4 North Dakota opinions naming this issue, 2005–2025
2 sentences

2025Dep’t of Transp., 530 N.W.2d 362, 365 (N.D. 1995) (“Section 39-20-03.1(3) distinguishes between breath tests on the one hand, and blood . . . and urine tests on the other.”). [¶28] In Bosch v. Moore, the driver was arrested for driving under the influence, and the officer conducted a breath test and a urine test. 517 N.W.2d 412, 412 (N.D. 1994).

2023In Bosch, the driver was arrested for driving under the influence (DUI) and administered two Intoxilyzer breath tests and a urine test. 517 N.W.2d at 412 .

14
Wingerter v. North Dakota Department of Transportationgreen
nd · 1995 · cited in 1 North Dakota opinions naming this issue, 2025–2025
1 sentence

2025Dep’t of Transp., 530 N.W.2d 362, 365 (N.D. 1995) (“Section 39-20-03.1(3) distinguishes between breath tests on the one hand, and blood . . . and urine tests on the other.”). [¶28] In Bosch v. Moore, the driver was arrested for driving under the influence, and the officer conducted a breath test and a urine test. 517 N.W.2d 412, 412 (N.D. 1994).

11
Birchfield v. N. Dakota. William Robert Bernardgreen
scotus · 2016 · cited in 1 North Dakota opinions naming this issue, 2020–2020
1 sentence

2020Cf. Birchfield v. North Dakota, 136 S. Ct. 2160, 2173 (2016) (stating taking a blood sample is a search and a warrant must usually be secured for a search to be “reasonable,” but a number of exceptions to the warrant requirement may apply).

11
Skinner v. Railway Labor Executives' Assn.green
scotus · 1989 · cited in 1 North Dakota opinions naming this issue, 2017–2017
2 sentences

2017See Skinner, 489 U.S. at 621-24 , 109 S.Ct. 1402 (discussing minimal discretion vested in those administering urine tests under federal railroad regulations); Von Raab, 489 U.S. at 661-62 , 109 S.Ct. 1384 (describing administration of urine tests under customs service program for drug testing).

2017See Skinner, 489 U.S. at 621-24 , 109 S.Ct. 1402 (discussing minimal discretion vested in those administering urine tests under federal railroad regulations); Von Raab, 489 U.S. at 661-62 , 109 S.Ct. 1384 (describing administration of urine tests under customs service program for drug testing).

11
State of Minnesota v. Ryan Mark Thompsongreen
minn · 2016 · cited in 1 North Dakota opinions naming this issue, 2017–2017
2 sentences

2017Thompson, at 232. [¶ 11] In balancing the arrestee’s privacy interests against the State’s need for evidence of a driver’s blood alcohol concentration, the Minnesota Supreme Court explained that “despite the State’s ‘great’ need for alcohol concentration testing, the availability of a less-invasive breath test weighs against the reasonableness of requiring the more revealing and embarrassing urine test absent a warrant or exigent circumstances.” Thompson , 886 N.W.2d at 233 .

2017See Thompson, 886 N.W.2d at 231 (citing Birchfield and Skinner and discussing broad scope of information revealed by urine tests).

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (5)

CaseCitedYears
City of Fargo v. Hofer neutral
nd · 2020
2 sentences

2025Id.; cf. City of Fargo v. Hofer, 2020 ND 252, ¶ 13 , 952 N.W.2d 58 (holding, despite obtaining a search warrant, because officer administered the urine test under N.D.C.C. § 39-20-01, the officer was required to inform defendant under N.D.C.C. § 39-20-01(3) for test results to be admissible in a criminal proceeding under the then-statutory exclusion).

2025Id.; cf. City of Fargo v. Hofer, 2020 ND 252, ¶ 13 , 952 N.W.2d 58 (holding, despite obtaining a search warrant, because officer administered the urine test under N.D.C.C. § 39-20-01, the officer was required to inform defendant under N.D.C.C. § 39-20-01(3) for test results to be admissible in a criminal proceeding under the then-statutory exclusion).

12025–2025
City of Bismarck v. Vagts green
nd · 2019
1 sentence

2020He contends the implied consent advisory omitted the phrase “directed by the law enforcement officer,” and under City of Bismarck v. Vagts, 2019 ND 224 , 932 N.W.2d 523 , the omitted phrase is a substantive omission and the advisory did not comply with statutory requirements.

12020–2020
State v. Bohe neutral
nd · 2018
2 sentences

2020While admitting the urine test results would be inadmissible if no search warrant had been obtained and served, the City contends the implied consent advisory is not relevant because a search warrant was obtained. [¶6] In reviewing a district court’s decision on a motion to suppress, “[w]e defer to the district court’s findings of fact and resolve conflicts in testimony in favor of affirmance.” Vagts, 2019 ND 224 , ¶ 4 (quoting State v. Bohe, 2018 ND 216, ¶ 9 , 917 N.W.2d 497 ).

2020While admitting the urine test results would be inadmissible if no search warrant had been obtained and served, the City contends the implied consent advisory is not relevant because a search warrant was obtained. [¶6] In reviewing a district court’s decision on a motion to suppress, “[w]e defer to the district court’s findings of fact and resolve conflicts in testimony in favor of affirmance.” Vagts, 2019 ND 224 , ¶ 4 (quoting State v. Bohe, 2018 ND 216, ¶ 9 , 917 N.W.2d 497 ).

12020–2020
State v. Helm green
nd · 2017
2 sentences

2019State v. Helm , 2017 ND 207 , ¶ 1, 901 N.W.2d 57 (determining that the collection of urine without a warrant, or an exception to the requirement to obtain a warrant, is an impermissible search).

2019State v. Helm , 2017 ND 207 , ¶ 1, 901 N.W.2d 57 (determining that the collection of urine without a warrant, or an exception to the requirement to obtain a warrant, is an impermissible search).

12019–2019
National Treasury Employees Union v. Von Raab green
scotus · 1989
2 sentences

2017See Skinner, 489 U.S. at 621-24 , 109 S.Ct. 1402 (discussing minimal discretion vested in those administering urine tests under federal railroad regulations); Von Raab, 489 U.S. at 661-62 , 109 S.Ct. 1384 (describing administration of urine tests under customs service program for drug testing).

2017See Skinner, 489 U.S. at 621-24 , 109 S.Ct. 1402 (discussing minimal discretion vested in those administering urine tests under federal railroad regulations); Von Raab, 489 U.S. at 661-62 , 109 S.Ct. 1384 (describing administration of urine tests under customs service program for drug testing).

12017–2017

Statutes the citing opinions construe

ND § N.D. Cent. Code § 39-20-01 (5) ND § N.D. Cent. Code § 39-20-03.1 (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

MN 45 (1933–2024) OH 35 (1986–2025) CA 34 (1972–2025) OR 25 (1989–2025) NY 23 (1973–2025) GA 22 (1978–2025) TX 14 (1972–2025) IL 13 (1978–2026) IA 12 (1978–2019) NE 10 (1990–2024) FL 10 (1990–2023) PA 8 (1989–2021) ND 8 (2005–2025) CT 7 (1988–2026) MO 7 (1997–2025) LA 6 (1983–2018) WI 5 (1991–2024) AZ 4 (1989–2014) NM 4 (1994–2017) IN 4 (1994–2020) NJ 4 (1993–2024) AR 4 (1965–2017) DC 3 (1966–2012) KY 3 (2015–2024) WA 3 (2008–2016) MT 3 (2005–2016) ME 3 (2002–2019) ID 2 (2010–2012) CO 2 (1993–1993) MI 2 (1999–2014)

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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