results of the HGN test (North Carolina) · Go Syfert
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results of the HGN test in North Carolina

7 North Carolina opinions name it 1 courts 2016–2025 3 in the last five years

The cases below were cited by North Carolina 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 (0)

CaseFollowedCited
No positive-treatment citations attached to this issue in North Carolina.

Distinguished, questioned or overruled (0)

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

Also cited on this issue (5)

CaseCitedYears
State v. Godwin green
nc · 2017
2 sentences

2025Our Supreme Court has stated that “with the 2006 amendment to Rule 702, our General Assembly clearly signaled that the results of the HGN test are sufficiently reliable to be admitted into the courts of this State.” State v. Godwin, 369 N.C. 604, 613 , 800 S.E.2d 47 , 53 (2017).

2021Theis testified that in his experience, HGN was accurate and a “very good tool to use for detection of impaired drivers.” Moreover, “our General Assembly [has] clearly signaled that the results of the HGN test are sufficiently reliable to be admitted into the courts of this State.” State v. Godwin, 369 N.C. 604, 613 , 800 S.E.2d 47 , 53 (2017) (citing N.C.

52017–2025
State v. Helms green
nc · 1998
2 sentences

2017BARKER Opinion of the Court Defendant relies heavily on the decision in State v. Helms, 348 N.C. 578 , 504 S.E.2d 293 (1998), which, critically, was decided prior to the General Assembly’s amendments to Rule 702 in 2006 and 2011, as well as the decision in McGrady.

2017Defendant relies heavily on the decision in State v. Helms , 348 N.C. 578 , 504 S.E.2d 293 (1998), which, critically, was decided prior to the General Assembly's amendments to Rule 702 in 2006 and 2011, as well as the decision in McGrady .

22016–2017
State v. Helms green
nc · 1998
2 sentences

2017BARKER Opinion of the Court Defendant relies heavily on the decision in State v. Helms, 348 N.C. 578 , 504 S.E.2d 293 (1998), which, critically, was decided prior to the General Assembly’s amendments to Rule 702 in 2006 and 2011, as well as the decision in McGrady.

2017Defendant relies heavily on the decision in State v. Helms , 348 N.C. 578 , 504 S.E.2d 293 (1998), which, critically, was decided prior to the General Assembly's amendments to Rule 702 in 2006 and 2011, as well as the decision in McGrady .

22016–2017
State v. Fincher green
ncctapp · 2018
1 sentence

2025After the 2011 amendment, our Court expanded on that ruling stating, “it is clear that the General Assembly has indicated its desire that Drug Recognition Evidence . . . be admitted, and that this type of evidence has already been determined to be reliable and based on sufficient facts and data.” Fincher, 259 N.C.

12025–2025
State v. Smart neutral
ncctapp · 2009
1 sentence

2017This holding is similar to this Court's holding in Smart that the 2006 amendment to Rule 702 "obviat[ed] the need for the State to prove that the HGN testing method is sufficiently reliable." Smart , 195 N.C.

12017–2017

Statutes the citing opinions construe

NC § N.C. Gen. Stat. § 8C-1 (7) NC § N.C. Gen. Stat. § 20-138.1 (4) NC § N.C. Gen. Stat. § 20-4.01 (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 43 (1992–2025) TX 23 (1989–2020) IL 21 (1992–2026) NC 7 (2016–2025) GA 6 (1996–2020) MO 5 (2007–2020) OR 4 (1993–2018) NM 4 (2002–2023) AZ 4 (1991–2014) MT 4 (1998–2025) WV 4 (1988–2002) PA 3 (1987–1995) KS 3 (1992–2020) CT 3 (1994–1994) NY 3 (1991–2017) CA 3 (1994–2018) AL 2 (1990–2004) MS 2 (1999–2004) MD 2 (1995–2005) ME 2 (1997–2009) CO 2 (2020–2021)

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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