BAC test (Idaho) · Go Syfert
← Idaho issues

BAC test in Idaho

46 Idaho opinions name it 2 courts 1990–2025 6 in the last five years

The cases below were cited by Idaho 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 (50)

CaseFollowedCited
State v. Sheltongreen
idahoctapp · 1997 · cited in 5 Idaho opinions naming this issue, 1998–2025
2 sentences

2025See State v. Cantrell, 139 Idaho 409, 412 , 80 P.3d 345, 348 (Ct. App. 2003) (the delay in release from jail was not attributable to the State because the officers were not interfering or preventing defendant’s release); State v. Shelton, 129 Idaho 877, 880 , 934 P.2d 943, 946 (Ct. App. 1997) (because defendant did not affirmatively exercise his right to an independent BAC test, the State did not violate his rights).

2025See State v. Cantrell, 139 Idaho 409, 412 , 80 P.3d 345, 348 (Ct. App. 2003) (the delay in release from jail was not attributable to the State because the officers were not interfering or preventing defendant’s release); State v. Shelton, 129 Idaho 877, 880 , 934 P.2d 943, 946 (Ct. App. 1997) (because defendant did not affirmatively exercise his right to an independent BAC test, the State did not violate his rights).

45
Matter of McNeelygreen
idahoctapp · 1990 · cited in 5 Idaho opinions naming this issue, 1995–2008
2 sentences

2008Under Idaho’s implied consent statute, I.C. § 18-8002(1), anyone driving on Idaho roads is deemed to have impliedly consented to evidentiary testing for the presence of alcohol or drugs when a police officer has reasonable cause to believe the person was driving under the influence. 2 In other words, “[b]y virtue of this statute, ‘anyone who accepts the privilege of operating a motor vehicle upon Idaho’s highways has consented in advance to submit to a BAC test.’ ” Rodriguez, 128 Idaho at 523 , 915 P.2d at 1381 (quoting Matter of McNeely, 119 Idaho 182, 187 , 804 P.2d 911, 916 (Ct.App. 1990)).

2008Under Idaho’s implied consent statute, I.C. § 18-8002(1), anyone driving on Idaho roads is deemed to have impliedly consented to evidentiary testing for the presence of alcohol or drugs when a police officer has reasonable cause to believe the person was driving under the influence. 2 In other words, “[b]y virtue of this statute, ‘anyone who accepts the privilege of operating a motor vehicle upon Idaho’s highways has consented in advance to submit to a BAC test.’ ” Rodriguez, 128 Idaho at 523 , 915 P.2d at 1381 (quoting Matter of McNeely, 119 Idaho 182, 187 , 804 P.2d 911, 916 (Ct.App. 1990)).

45
State v. Carrgreen
idahoctapp · 1995 · cited in 8 Idaho opinions naming this issue, 1997–2025
2 sentences

2020Applying the first factor listed above, the Court of Appeals explained that the private interest at stake was the arrested individual’s interest in “procuring evidence which would challenge the results of the State’s BAC test.” Id. at 184 , 911 P.2d at 777 .

2020Applying the first factor listed above, the Court of Appeals explained that the private interest at stake was the arrested individual’s interest in “procuring evidence which would challenge the results of the State’s BAC test.” Id. at 184 , 911 P.2d at 777 .

38
State v. Maddengreen
idahoctapp · 1995 · cited in 4 Idaho opinions naming this issue, 1995–2010
2 sentences

1997Medley, supra. Relying on State v. Carr, 128 Idaho 181 , 911 P.2d 774 (Ct.App.1995), and State v. Madden, 127 Idaho 894 , 908 P.2d 587 (Ct.App.1995), Shelton asserts that his right to due process was violated because the standard Advisory Form was defective in two ways: first, the form faded to advise the detainee that immediately following the BAC test, access to a telephone is available for the purposes of arranging bail, contacting an attorney or arranging additional BAC testing; and second, the form failed to advise the detainee that if he requested additional BAC testing, an officer would

1997Medley, supra. Relying on State v. Carr, 128 Idaho 181 , 911 P.2d 774 (Ct.App.1995), and State v. Madden, 127 Idaho 894 , 908 P.2d 587 (Ct.App.1995), Shelton asserts that his right to due process was violated because the standard Advisory Form was defective in two ways: first, the form faded to advise the detainee that immediately following the BAC test, access to a telephone is available for the purposes of arranging bail, contacting an attorney or arranging additional BAC testing; and second, the form failed to advise the detainee that if he requested additional BAC testing, an officer would

24
State v. Maddengreen
idahoctapp · 1995 · cited in 4 Idaho opinions naming this issue, 1995–2010
2 sentences

1997Medley, supra. Relying on State v. Carr, 128 Idaho 181 , 911 P.2d 774 (Ct.App.1995), and State v. Madden, 127 Idaho 894 , 908 P.2d 587 (Ct.App.1995), Shelton asserts that his right to due process was violated because the standard Advisory Form was defective in two ways: first, the form faded to advise the detainee that immediately following the BAC test, access to a telephone is available for the purposes of arranging bail, contacting an attorney or arranging additional BAC testing; and second, the form failed to advise the detainee that if he requested additional BAC testing, an officer would

1997Medley, supra. Relying on State v. Carr, 128 Idaho 181 , 911 P.2d 774 (Ct.App.1995), and State v. Madden, 127 Idaho 894 , 908 P.2d 587 (Ct.App.1995), Shelton asserts that his right to due process was violated because the standard Advisory Form was defective in two ways: first, the form faded to advise the detainee that immediately following the BAC test, access to a telephone is available for the purposes of arranging bail, contacting an attorney or arranging additional BAC testing; and second, the form failed to advise the detainee that if he requested additional BAC testing, an officer would

24
State v. Cantrellgreen
idahoctapp · 2003 · cited in 3 Idaho opinions naming this issue, 2007–2025
2 sentences

2025See State v. Cantrell, 139 Idaho 409, 412 , 80 P.3d 345, 348 (Ct. App. 2003) (the delay in release from jail was not attributable to the State because the officers were not interfering or preventing defendant’s release); State v. Shelton, 129 Idaho 877, 880 , 934 P.2d 943, 946 (Ct. App. 1997) (because defendant did not affirmatively exercise his right to an independent BAC test, the State did not violate his rights).

2025See State v. Cantrell, 139 Idaho 409, 412 , 80 P.3d 345, 348 (Ct. App. 2003) (the delay in release from jail was not attributable to the State because the officers were not interfering or preventing defendant’s release); State v. Shelton, 129 Idaho 877, 880 , 934 P.2d 943, 946 (Ct. App. 1997) (because defendant did not affirmatively exercise his right to an independent BAC test, the State did not violate his rights).

23
State v. Ankneygreen
idaho · 1985 · cited in 3 Idaho opinions naming this issue, 1990–1995
2 sentences

1992See, e.g., State v. Woolery, 116 Idaho 368 , 775 P.2d 1210 (1989) (holding that there is no statutory right to refuse to submit to an evidentiary test for BAC); I.C. § 18-8002(2) (providing that when an officer has statutory grounds for requesting a BAC test of a driver, that “person *370 shall not have the right to consult with an attorney before submitting to [the test.]”) See also State v. Ankney, 109 Idaho 1 , 704 P.2d 333 (1985).

1992See, e.g., State v. Woolery, 116 Idaho 368 , 775 P.2d 1210 (1989) (holding that there is no statutory right to refuse to submit to an evidentiary test for BAC); I.C. § 18-8002(2) (providing that when an officer has statutory grounds for requesting a BAC test of a driver, that “person *370 shall not have the right to consult with an attorney before submitting to [the test.]”) See also State v. Ankney, 109 Idaho 1 , 704 P.2d 333 (1985).

23
State v. Greengreen
idahoctapp · 2010 · cited in 2 Idaho opinions naming this issue, 2020–2025
2 sentences

2020While it is true that a DUI arrestee has no right to access a phone or to call a lawyer before a BAC test is administered, State v. Green, 149 Idaho 706, 710 , 239 P.3d 811, 815 (Ct. App. 2010), such a request can still help to inform State actors as to the purpose of a subsequent request.

2020While it is true that a DUI arrestee has no right to access a phone or to call a lawyer before a BAC test is administered, State v. Green, 149 Idaho 706, 710 , 239 P.3d 811, 815 (Ct. App. 2010), such a request can still help to inform State actors as to the purpose of a subsequent request.

22
Masterson v. Idaho Department of Transportationgreen
idahoctapp · 2010 · cited in 2 Idaho opinions naming this issue, 2022–2024
2 sentences

2024See id. at 129 , 244 P.3d at 628 .

2024See id. at 129 , 244 P.3d at 628 .

22
State v. Rountreegreen
idahoctapp · 1996 · cited in 2 Idaho opinions naming this issue, 2007–2010
2 sentences

2010Hedges, 143 Idaho at 887-88 , 154 P. 3d at 1077-78 ; see also Rountree, 129 Idaho at 150 , 922 P.2d at 1076 . 3 At the hearing on the motion to suppress, Blackmon testified that he asked the arresting officer for a second BAC test and a telephone call soon after submitting to the BAC test.

2010Hedges, 143 Idaho at 887-88 , 154 P. 3d at 1077-78 ; see also Rountree, 129 Idaho at 150 , 922 P.2d at 1076 . 3 At the hearing on the motion to suppress, Blackmon testified that he asked the arresting officer for a second BAC test and a telephone call soon after submitting to the BAC test.

22
State v. Hedgesgreen
idahoctapp · 2007 · cited in 4 Idaho opinions naming this issue, 2010–2025
2 sentences

2025Hedges, 143 Idaho at 888 , 154 P.3d at 1078 (once informed of this right, a defendant must make a clear and unambiguous statement of his or her desire to obtain an independent BAC test, such that a reasonable police officer under the circumstances would understand the statement to be an affirmative assertion thereof).

2025Hedges, 143 Idaho at 888 , 154 P.3d at 1078 (once informed of this right, a defendant must make a clear and unambiguous statement of his or her desire to obtain an independent BAC test, such that a reasonable police officer under the circumstances would understand the statement to be an affirmative assertion thereof).

14
State v. Bellgreen
idahoctapp · 1988 · cited in 3 Idaho opinions naming this issue, 1990–2013
2 sentences

2013With respect to the ISP’s responsibility to adopt standards that will ensure test accuracy, Besaw refers to this Court’s comments in State v. Bell, 115 Idaho 36 , 764 P.2d 113 (Ct.App.1988), discussing a prior version of I.C. § 18-8004 in which responsibility for authorizing alcohol content testing procedures was assigned to the Idaho Department of Health and Welfare, a responsibility that has subsequently transferred to the ISP.

2013With respect to the ISP’s responsibility to adopt standards that will ensure test accuracy, Besaw refers to this Court’s comments in State v. Bell, 115 Idaho 36 , 764 P.2d 113 (Ct.App.1988), discussing a prior version of I.C. § 18-8004 in which responsibility for authorizing alcohol content testing procedures was assigned to the Idaho Department of Health and Welfare, a responsibility that has subsequently transferred to the ISP.

13
State v. Swansongreen
mont · 1986 · cited in 2 Idaho opinions naming this issue, 1995–2010
2 sentences

2010Snyder v. State, 930 P.2d 1274, 1277 (Alaska 1996); McNutt v. Superior Court of State of Arizona, 133 Ariz. 7, 648 P.2d 122 , 125 n. 2 (1982); Smith v. Cada, 114 Ariz. 510 , 562 P.2d 390, 392-93 (Ariz.Ct.App.1977); State v. Swanson, 222 Mont. 357 , 722 P.2d 1155, 1157 (1986); State v. Lewis, 266 S.C. 45 , 221 S.E.2d 524, 526 (1976).

2010Snyder v. State, 930 P.2d 1274, 1277 (Alaska 1996); McNutt v. Superior Court of State of Arizona, 133 Ariz. 7, 648 P.2d 122 , 125 n. 2 (1982); Smith v. Cada, 114 Ariz. 510 , 562 P.2d 390, 392-93 (Ariz.Ct.App.1977); State v. Swanson, 222 Mont. 357 , 722 P.2d 1155, 1157 (1986); State v. Lewis, 266 S.C. 45 , 221 S.E.2d 524, 526 (1976).

12
Matter of Griffithsgreen
idaho · 1987 · cited in 2 Idaho opinions naming this issue, 1990–2010
2 sentences

2010Griffiths, 113 Idaho at 370 , 744 P.2d at 98 . 5 comply with the statutory directive concerning the advisory information to be given to motorists when a BAC test is requested.

2010Griffiths, 113 Idaho at 370 , 744 P.2d at 98 . 5 comply with the statutory directive concerning the advisory information to be given to motorists when a BAC test is requested.

12
State v. Rodriguezgreen
idahoctapp · 1996 · cited in 2 Idaho opinions naming this issue, 2008–2010
2 sentences

2010In other words, “[b]y virtue of this statute, anyone who accepts the privilege of operating a motor vehicle upon Idaho’s highways has consented in advance to submit to a BAC test.” DeWitt, 145 Idaho at 712 , 184 P.3d at 218 (quoting State v. Rodriguez, 128 Idaho 521, 523 , 915 P.2d 1379, 1381 (Ct.App.1996) (internal quotations omitted)).

2010In other words, “[b]y virtue of this statute, anyone who accepts the privilege of operating a motor vehicle upon Idaho’s highways has consented in advance to submit to a BAC test.” DeWitt, 145 Idaho at 712 , 184 P.3d at 218 (quoting State v. Rodriguez, 128 Idaho 521, 523 , 915 P.2d 1379, 1381 (Ct.App.1996) (internal quotations omitted)).

12
State v. Wooleryred
idaho · 1989 · cited in 2 Idaho opinions naming this issue, 1992–1999
2 sentences

1992See, e.g., State v. Woolery, 116 Idaho 368 , 775 P.2d 1210 (1989) (holding that there is no statutory right to refuse to submit to an evidentiary test for BAC); I.C. § 18-8002(2) (providing that when an officer has statutory grounds for requesting a BAC test of a driver, that “person *370 shall not have the right to consult with an attorney before submitting to [the test.]”) See also State v. Ankney, 109 Idaho 1 , 704 P.2d 333 (1985).

1992See, e.g., State v. Woolery, 116 Idaho 368 , 775 P.2d 1210 (1989) (holding that there is no statutory right to refuse to submit to an evidentiary test for BAC); I.C. § 18-8002(2) (providing that when an officer has statutory grounds for requesting a BAC test of a driver, that “person *370 shall not have the right to consult with an attorney before submitting to [the test.]”) See also State v. Ankney, 109 Idaho 1 , 704 P.2d 333 (1985).

12
State v. Stegallgreen
idaho · 2020 · cited in 1 Idaho opinions naming this issue, 2025–2025
2 sentences

2025State v. Hedges, 143 Idaho, 844, 888 , 154 P.3d 1074, 1078 (Ct. App. 2007). 2 As the district court noted, the Court in Stegall stated that a DUI suspect’s request to call an attorney prior to a BAC test “can still help to inform State actors as to the purpose of a subsequent request.” State v. Stegall, 167 Idaho 918, 924 , 477 P.3d 972, 978 (2020).

2025State v. Hedges, 143 Idaho, 844, 888 , 154 P.3d 1074, 1078 (Ct. App. 2007). 2 As the district court noted, the Court in Stegall stated that a DUI suspect’s request to call an attorney prior to a BAC test “can still help to inform State actors as to the purpose of a subsequent request.” State v. Stegall, 167 Idaho 918, 924 , 477 P.3d 972, 978 (2020).

11
State v. Hendersongreen
idaho · 1988 · cited in 1 Idaho opinions naming this issue, 2024–2024
2 sentences

2024See State v. Henderson, 114 Idaho 293, 295 , 756 P.2d 1057, 1059 (1988); Ferreira, 133 Idaho at 490 , 988 P.2d at 706 .

2024See State v. Henderson, 114 Idaho 293, 295 , 756 P.2d 1057, 1059 (1988); Ferreira, 133 Idaho at 490 , 988 P.2d at 706 .

11
BMW of North America, Inc. v. Goregreen
scotus · 1996 · cited in 1 Idaho opinions naming this issue, 2023–2023
1 sentence

2023Wood’s above factual contentions certainly “raise a suspicious judicial eyebrow[.]” BMW of N. Am., Inc. v. Gore, 517 U.S. 559, 583 (1996) (quoting TXO Prod.

11
State v. Carsongreen
idahoctapp · 1999 · cited in 1 Idaho opinions naming this issue, 2023–2023
2 sentences

2023See, e.g., State v. Carson, 133 Idaho 451 , 452–53, 988 P.2d 225 , 226–27 (Ct. App. 1999) (quoting the manual approved by the Department of Law Enforcement [predecessor agency to the ISP] as requiring the officer administering a BAC test to “[o]bserve the subject for 15 minutes” and that “[d]uring this time, the subject may not smoke, consume alcohol, belch, vomit, use chewing tobacco, or have any other substance in the mouth.” (emphasis added)); Wilkinson v. State, Dept. of Transp., 151 Idaho 784 , 264 P.3d 680 (Ct. App. 2011) (quoting the operator’s training manual for the Intoxilyzer 5000 a

2023See, e.g., State v. Carson, 133 Idaho 451 , 452–53, 988 P.2d 225 , 226–27 (Ct. App. 1999) (quoting the manual approved by the Department of Law Enforcement [predecessor agency to the ISP] as requiring the officer administering a BAC test to “[o]bserve the subject for 15 minutes” and that “[d]uring this time, the subject may not smoke, consume alcohol, belch, vomit, use chewing tobacco, or have any other substance in the mouth.” (emphasis added)); Wilkinson v. State, Dept. of Transp., 151 Idaho 784 , 264 P.3d 680 (Ct. App. 2011) (quoting the operator’s training manual for the Intoxilyzer 5000 a

11
State v. Vlietgreen
haw · 2001 · cited in 1 Idaho opinions naming this issue, 2020–2020
11
Verska v. Saint Alphonsus Regional Medical Centergreen
idaho · 2011 · cited in 1 Idaho opinions naming this issue, 2020–2020
11
State v. Davisgreen
ncctapp · 2001 · cited in 1 Idaho opinions naming this issue, 2020–2020
11
State v. Daygreen
nm · 2008 · cited in 1 Idaho opinions naming this issue, 2020–2020
11
State v. Trujillogreen
orctapp · 2015 · cited in 1 Idaho opinions naming this issue, 2020–2020
11
State v. Felicity Kathleen Haynesgreen
idaho · 2015 · cited in 1 Idaho opinions naming this issue, 2016–2016
11
South Dakota v. Nevillegreen
scotus · 1983 · cited in 1 Idaho opinions naming this issue, 2015–2015
11
Wanner v. State, Department of Transportationgreen
idaho · 2011 · cited in 1 Idaho opinions naming this issue, 2012–2012
11
Virgil v. Stategreen
idahoctapp · 1995 · cited in 1 Idaho opinions naming this issue, 2010–2010
11
Smith v. Cadagreen
arizctapp · 1977 · cited in 1 Idaho opinions naming this issue, 2010–2010
11
Snyder v. Stategreen
alaska · 1996 · cited in 1 Idaho opinions naming this issue, 2010–2010
11
State v. Lewisgreen
sc · 1976 · cited in 1 Idaho opinions naming this issue, 2010–2010
11
State v. Diazred
idaho · 2007 · cited in 1 Idaho opinions naming this issue, 2008–2008
11
Davis v. United Statesgreen
scotus · 1994 · cited in 1 Idaho opinions naming this issue, 2007–2007
11
State v. Mooregreen
idaho · 1998 · cited in 1 Idaho opinions naming this issue, 2005–2005
11
State v. Knollgreen
idahoctapp · 1986 · cited in 1 Idaho opinions naming this issue, 2005–2005
11
State v. Barkergreen
idahoctapp · 1992 · cited in 1 Idaho opinions naming this issue, 2005–2005
11
Giles v. Stategreen
idaho · 1994 · cited in 1 Idaho opinions naming this issue, 2005–2005
11
Schmerber v. Californiagreen
scotus · 1966 · cited in 1 Idaho opinions naming this issue, 1999–1999
11
Bilbrey v. Stategreen
alacrimapp · 1988 · cited in 1 Idaho opinions naming this issue, 1995–1995
11

Distinguished, questioned or overruled (0)

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

Also cited on this issue (22)

CaseCitedYears
Missouri v. McNeely green
scotus · 2013
2 sentences

2020The Court stated, “[s]uch laws impose significant consequences when a motorist withdraws consent; typically the motorist’s driver’s license is immediately suspended or revoked, and most States allow the motorist’s refusal to take a BAC test to be used as evidence against him in a subsequent criminal prosecution.” Id.

2020The Court stated, “[s]uch laws impose significant consequences when a motorist withdraws consent; typically the motorist’s driver’s license is immediately suspended or revoked, and most States allow the motorist’s refusal to take a BAC test to be used as evidence against him in a subsequent criminal prosecution.” Id.

52014–2020
State of Idaho, Department of Transportation v. Marvin Gibbar green
idahoctapp · 2006
2 sentences

2012In Gibbar, we interpreted Idaho Code § 18 -8002A(7)(c) and (d) “as permitting [administrative license suspension] petitioners to challenge the results of their BAC test by proving that the testing equipment was inaccurate or was not functioning properly because the State has adopted procedures that do not ensure accuracy and proper functioning.” Gibbar, 143 Idaho at 947 , 155 P.3d at 1186 .

2012In Gibbar, we interpreted Idaho Code § 18 -8002A(7)(e) and (d) “as permitting [administrative license suspension] petitioners to challenge the results of their BAC test by proving that the testing equipment was inaccurate or was not functioning properly because the State has adopted procedures that do not ensure accuracy and proper functioning.” Gibbar, 143 Idaho at 947 , 155 P.3d at 1186 .

42011–2012
In Re Suspension of Driver's License green
idahoctapp · 2006
2 sentences

2012In Gibbar, we interpreted Idaho Code § 18 -8002A(7)(c) and (d) “as permitting [administrative license suspension] petitioners to challenge the results of their BAC test by proving that the testing equipment was inaccurate or was not functioning properly because the State has adopted procedures that do not ensure accuracy and proper functioning.” Gibbar, 143 Idaho at 947 , 155 P.3d at 1186 .

2012In Gibbar, we interpreted Idaho Code § 18 -8002A(7)(e) and (d) “as permitting [administrative license suspension] petitioners to challenge the results of their BAC test by proving that the testing equipment was inaccurate or was not functioning properly because the State has adopted procedures that do not ensure accuracy and proper functioning.” Gibbar, 143 Idaho at 947 , 155 P.3d at 1186 .

42011–2012
State v. Robinett green
idaho · 2005
2 sentences

2025Clapp also argues that the district court erred by allowing his BAC test results to be considered as evidence on the impairment theory of DUI without any evidence extrapolating those results back to the time of driving, contrary to State v. Robinett, 141 Idaho 110 , 106 P.3d 436 (2005).1 The State responds that a review of the record and relevant law 1 Clapp also cites our unpublished opinion in State v. Hollon, Docket No. 46241 (Ct. App. Dec. 23, 2019), asserting that, although Hollon does “not constitute precedent” and claiming he does not rely on it “as authority requiring a particular deci

2025Clapp also argues that the district court erred by allowing his BAC test results to be considered as evidence on the impairment theory of DUI without any evidence extrapolating those results back to the time of driving, contrary to State v. Robinett, 141 Idaho 110 , 106 P.3d 436 (2005).1 The State responds that a review of the record and relevant law 1 Clapp also cites our unpublished opinion in State v. Hollon, Docket No. 46241 (Ct. App. Dec. 23, 2019), asserting that, although Hollon does “not constitute precedent” and claiming he does not rely on it “as authority requiring a particular deci

32016–2025
State v. Sutliff green
idaho · 1976
2 sentences

2020Ctr., 151 Idaho 889 , 265 P.3d 502 (2011); Sutliff, 97 Idaho at 525 , 547 P.2d at 1130 . 9 (“[R]etrograde analysis is generally considered to be a reliable scientific discipline.”); State v. Vliet, 19 P.3d 42, 60 (Haw. 2001) (“We take judicial notice that Widmark’s formula is widely viewed as reliable.”); State v. Day, 176 P.3d 1091, 1099 (N.M. 2008) (“[T]he State can use scientific retrograde extrapolation evidence to prove that a BAC test taken after three hours and below 0.08 shows that the defendant had an actual BAC of 0.08 or higher within three hours of driving.”); State v. Davis, 542 S

2020Ctr., 151 Idaho 889 , 265 P.3d 502 (2011); Sutliff, 97 Idaho at 525 , 547 P.2d at 1130 . 9 (“[R]etrograde analysis is generally considered to be a reliable scientific discipline.”); State v. Vliet, 19 P.3d 42, 60 (Haw. 2001) (“We take judicial notice that Widmark’s formula is widely viewed as reliable.”); State v. Day, 176 P.3d 1091, 1099 (N.M. 2008) (“[T]he State can use scientific retrograde extrapolation evidence to prove that a BAC test taken after three hours and below 0.08 shows that the defendant had an actual BAC of 0.08 or higher within three hours of driving.”); State v. Davis, 542 S

22005–2020
State v. Hartwig green
idahoctapp · 1987
2 sentences

2012Similarly, in State v. Hartwig, 112 Idaho 370 , 732 P.2d 339 (Ct. App. 1987), we held that although breath test results were properly admitted into evidence at a criminal trial because the State showed that the designated state agency had approved the machine for use and that the machine was operated in compliance with approved standards, the reliability and performance of the machine is still subject to challenge.

2012Similarly, in State v. Hartwig, 112 Idaho 370 , 732 P.2d 339 (Ct. App. 1987), we held that although breath test results were properly admitted into evidence at a criminal trial because the State showed that the designated state agency had approved the machine for use and that the machine was operated in compliance with approved standards, the reliability and performance of the machine is still subject to challenge.

22012–2012
McNutt v. Superior Court of State of Ariz. green
ariz · 1982
2 sentences

2010Snyder v. State, 930 P.2d 1274, 1277 (Alaska 1996); McNutt v. Superior Court of State of Arizona, 133 Ariz. 7, 648 P.2d 122 , 125 n. 2 (1982); Smith v. Cada, 114 Ariz. 510 , 562 P.2d 390, 392-93 (Ariz.Ct.App.1977); State v. Swanson, 222 Mont. 357 , 722 P.2d 1155, 1157 (1986); State v. Lewis, 266 S.C. 45 , 221 S.E.2d 524, 526 (1976).

2010Snyder v. State, 930 P.2d 1274, 1277 (Alaska 1996); McNutt v. Superior Court of State of Arizona, 133 Ariz. 7, 648 P.2d 122 , 125 n. 2 (1982); Smith v. Cada, 114 Ariz. 510 , 562 P.2d 390, 392-93 (Ariz.Ct.App.1977); State v. Swanson, 222 Mont. 357 , 722 P.2d 1155, 1157 (1986); State v. Lewis, 266 S.C. 45 , 221 S.E.2d 524, 526 (1976).

21995–2010
State v. Justin Keith Austin green
· 2018
1 sentence

2025However, on appeal, the Idaho Supreme Court clarified that, while BAC test results are sufficient for the State to show a driver was above the legal limit, the test result “does not act to remove the violation’s nexus to driving, nor does it mandate an unassailable conclusion not open to defense.” Id. at 381-82, 413 P.3d at 781-82 .

12025–2025
State v. Ferreira green
idahoctapp · 1999
2 sentences

2024See State v. Henderson, 114 Idaho 293, 295 , 756 P.2d 1057, 1059 (1988); Ferreira, 133 Idaho at 490 , 988 P.2d at 706 .

2024See State v. Henderson, 114 Idaho 293, 295 , 756 P.2d 1057, 1059 (1988); Ferreira, 133 Idaho at 490 , 988 P.2d at 706 .

12024–2024
Wilkinson v. State, Department of Transportation green
idahoctapp · 2011
2 sentences

2023See, e.g., State v. Carson, 133 Idaho 451 , 452–53, 988 P.2d 225 , 226–27 (Ct. App. 1999) (quoting the manual approved by the Department of Law Enforcement [predecessor agency to the ISP] as requiring the officer administering a BAC test to “[o]bserve the subject for 15 minutes” and that “[d]uring this time, the subject may not smoke, consume alcohol, belch, vomit, use chewing tobacco, or have any other substance in the mouth.” (emphasis added)); Wilkinson v. State, Dept. of Transp., 151 Idaho 784 , 264 P.3d 680 (Ct. App. 2011) (quoting the operator’s training manual for the Intoxilyzer 5000 a

2023See, e.g., State v. Carson, 133 Idaho 451 , 452–53, 988 P.2d 225 , 226–27 (Ct. App. 1999) (quoting the manual approved by the Department of Law Enforcement [predecessor agency to the ISP] as requiring the officer administering a BAC test to “[o]bserve the subject for 15 minutes” and that “[d]uring this time, the subject may not smoke, consume alcohol, belch, vomit, use chewing tobacco, or have any other substance in the mouth.” (emphasis added)); Wilkinson v. State, Dept. of Transp., 151 Idaho 784 , 264 P.3d 680 (Ct. App. 2011) (quoting the operator’s training manual for the Intoxilyzer 5000 a

12023–2023
State v. Gusman green
idaho · 1994
12019–2019
Peck v. State, Department of Transportation green
idahoctapp · 2012
12014–2014
State v. Schmoll green
idahoctapp · 2007
12010–2010
State v. Harmon green
idahoctapp · 1998
12010–2010
State v. DeWitt green
idahoctapp · 2008
12010–2010
Brady v. Maryland green
scotus · 1963
11998–1998
State v. Choate green
tenncrimapp · 1983
11995–1995
Scarborough v. State green
miss · 1972
11995–1995
City of Lakewood v. Waselenchuk green
ohioctapp · 1994
11995–1995
Anderson v. City of Pocatello green
idaho · 1987
11994–1994
Matter of Heth green
idahoctapp · 1988
11993–1993
McCharles v. State, Dept. of Motor Vehicles green
nev · 1983
11990–1990

Statutes the citing opinions construe

ID § Idaho Code § 18-8004 (42) ID § Idaho Code § 18-8002 (24) ID § Idaho Code § 18-8002A (14) ID § Idaho Code § 18-8006 (10) ID § Idaho Code § 67-5279 (7) ID § Idaho Code § 12-117 (5) ID § Idaho Code § 18-4006 (4) ID § Idaho Code § 18-705 (4) ID § Idaho Code § 18-8004C (4) ID § Idaho Code § 49-201 (4) ID § Idaho Code § 67-5251 (4) ID § Idaho Code § 18-8005 (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 95 (1991–2020) PA 86 (1992–2026) ID 46 (1990–2025) TX 37 (1999–2024) NM 36 (1993–2025) MO 27 (1992–2019) IL 20 (1999–2025) WA 19 (1989–2016) CO 19 (1987–2025) HI 19 (1996–2025) OR 18 (1993–2025) CA 17 (1992–2025) AZ 15 (1990–2024) IN 11 (1988–2018) MT 11 (1992–2021) MS 10 (1997–2023) VT 10 (1989–2018) NJ 8 (1990–2015) TN 7 (2009–2025) NY 7 (2013–2026) VA 6 (2004–2024) WI 6 (1997–2021) DE 6 (1988–2024) SC 6 (1997–2023) KS 5 (1993–2020) NH 4 (1985–2021) AL 4 (2011–2023) GA 4 (2015–2023) MI 4 (2006–2025) CT 4 (1992–1996) MN 4 (2014–2018) KY 3 (2007–2021) RI 3 (1998–2021) NC 3 (2017–2019) LA 3 (1995–2024) ND 3 (1993–2015) MD 3 (1995–2007) FL 3 (2014–2017) IA 3 (2017–2017) MA 2 (1993–2020) WY 2 (2014–2020) AR 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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