horizontal gaze nystagmus test (Pennsylvania) · Go Syfert
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horizontal gaze nystagmus test in Pennsylvania

7 Pennsylvania opinions name it 3 courts 1987–2024 3 in the last five years

The cases below were cited by Pennsylvania 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 (4)

CaseFollowedCited
Commonwealth v. Conwaygreen
pa · 1987 · cited in 2 Pennsylvania opinions naming this issue, 2023–2024
2 sentences

2024See Commonwealth v. Conway, 534 A.2d 541 , 542 n.1 (Pa. Super. 1987). -2- J-S34041-23 laned for traffic, and found him not guilty of the remaining offense.

2023See Commonwealth v. Conway, 534 A.2d 541 , 542 n.1 (Pa. Super. 1987). -2- J-S34041-23 found him not guilty of the remaining offense.

22
Commonwealth v. Weavergreen
pasuperct · 2013 · cited in 1 Pennsylvania opinions naming this issue, 2016–2016
1 sentence

2016See Commonwealth v. Weaver, 76 A.3d 562, 568 (Pa.Super. 2013) (police had probable cause to arrest for driving under the influence of a narcotic where an identified concerned citizen reported that appellant’s car was weaving and crossing into the oncoming lane of traffic; trooper followed Appellant and initiated a stop after he observed erratic driving; appellant appeared sluggish and was slow to respond to commands; appellant had an injured leg and could not perform the other field sobriety tests so trooper twice administered the horizontal gaze nystagmus test, which revealed that appellant’s

11
Commonwealth v. Speightsgreen
pa · 1986 · cited in 1 Pennsylvania opinions naming this issue, 1987–1987
2 sentences

1987Commonwealth v. Speights, 353 Pa.Super. 258, 262 , 509 A.2d 1263, 1265 (1986).

1987Commonwealth v. Speights, 353 Pa.Super. 258, 262 , 509 A.2d 1263, 1265 (1986).

11
Schmerber v. Californiagreen
scotus · 1966 · cited in 1 Pennsylvania opinions naming this issue, 1987–1987
2 sentences

1987See Schmerber v. California, 384 U.S. 757, 763-64 , 86 S.Ct. 1826, 1831-32 , 16 L.Ed.2d 908 (1966) (courts have usually held that the protection of the privilege does not extend to compulsory fingerprinting, photographs, measurements, writing or speaking for identification, appearing in court, assuming a particular stance, walking or making a particular gesture because the privilege is not violated by compulsion which makes a suspect the source of physical evidence). [4] For instance, after the officer administered the horizontal gaze nystagmus test, Mr. Conway asked, "Did I pass?" N.T., Septe

1987See Schmerber v. California, 384 U.S. 757, 763-64 , 86 S.Ct. 1826, 1831-32 , 16 L.Ed.2d 908 (1966) (courts have usually held that the protection of the privilege does not extend to compulsory fingerprinting, photographs, measurements, writing or speaking for identification, appearing in court, assuming a particular stance, walking or making a particular gesture because the privilege is not violated by compulsion which makes a suspect the source of physical evidence). [4] For instance, after the officer administered the horizontal gaze nystagmus test, Mr. Conway asked, "Did I pass?" N.T., Septe

11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (3)

CaseCitedYears
Banner v. COM., DEPT. OF TRANSP. green
pa · 1999
1 sentence

2021Banner v. Department of Transportation, Bureau of Driver Licensing, 737 A.2d 1203 (Pa. 1999). 3 “The horizontal gaze nystagmus test is a standard test used by police officers to determine whether a subject is intoxicated.

12021–2021
Commonwealth v. Gause green
pasuperct · 2017
2 sentences

2020Commonwealth v. Gause, 164 A.3d 532 , 535 n.5 (Pa. Super. 2017). - 11 - J-S73001-19 Q.

2020Commonwealth v. Gause, 164 A.3d 532 , 535 n.5 (Pa. Super. 2017). - 11 - J-S73001-19 Q.

12020–2020
Commonwealth v. Apollo green
pasuperct · 1992
2 sentences

1993Later, in Commonwealth v. Apollo, 412 Pa.Super. 453 , 603 A.2d 1023 (1992), allocatur denied, 531 Pa. 650 , 613 A.2d 556 (1992), the Court held that the trial court had not abused its discretion where, despite testimony of a behavioral optometrist, it concluded from other evidence that the reliability of the horizontal gaze nystagmus test was not a settled proposition within the scientific community and ruled the evidence inadmissible.

1993Later, in Commonwealth v. Apollo, 412 Pa.Super. 453 , 603 A.2d 1023 (1992), allocatur denied, 531 Pa. 650 , 613 A.2d 556 (1992), the Court held that the trial court had not abused its discretion where, despite testimony of a behavioral optometrist, it concluded from other evidence that the reliability of the horizontal gaze nystagmus test was not a settled proposition within the scientific community and ruled the evidence inadmissible.

11993–1993

Statutes the citing opinions construe

PA § 75 Pa. Cons. Stat. § 1547 (3) PA § 75 Pa. Cons. Stat. § 3731 (3) PA § 75 Pa. Cons. Stat. § 3802 (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 48 (1994–2024) OH 42 (1990–2024) CT 24 (1994–2025) WV 15 (1990–2023) MO 15 (1998–2025) IL 13 (1988–2025) GA 12 (2001–2024) OR 12 (1987–2025) NY 11 (1996–2025) TN 11 (1998–2017) MS 9 (1994–2022) MD 9 (1995–2024) WA 8 (1994–2025) AZ 7 (1986–2025) LA 7 (1990–2007) PA 7 (1987–2024) IA 6 (1990–2023) CA 6 (1990–2019) NC 5 (2000–2020) AR 4 (1992–2012) WY 4 (2000–2019) HI 4 (2007–2026) AK 3 (1998–2021) CO 3 (2019–2024) NJ 3 (2003–2026) MA 2 (1997–1998) ND 2 (1999–2018) FL 2 (1997–1997) WI 2 (2012–2024) NE 2 (2020–2020)

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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