alcohol breath test (Pennsylvania) · Go Syfert
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alcohol breath test in Pennsylvania

6 Pennsylvania opinions name it 1 courts 1999–2026 2 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 (2)

CaseFollowedCited
Commonwealth v. Snellgreen
pasuperct · 2002 · cited in 2 Pennsylvania opinions naming this issue, 2017–2019
2 sentences

2019Further, this Court has held “the Commonwealth must prove, by a preponderance of the evidence, that an individual subjected to a breathalyzer test did not ingest anything for the 20 minutes prior to administration of the test, but that ‘observation,’ as used in 67 Pa. Code § 77.24 (a), did not mean ‘eyes on his mouth 100% of the time.’” Commonwealth v. Snell, 811 A.2d 581, 586 (Pa. Super. 2002) (citing Barlow, 776 A.2d at 275 ).

2017“In [ Barlow, supra], we stated the Commonwealth must prove, by a preponderance of the evidence, that an individual subjected to a breathalyzer test did not ingest anything for the [twenty] minutes prior to administration of the test, but that ‘observation,’ as used in 67 Pa.Code § 77.24(a), did not mean ‘eyes on his mouth 100% of the time.’” Commonwealth v. Snell, 811 A.2d 581, 586 (Pa. Super. 2002), appeal denied, 820 A.2d 162 (Pa. 2003).

22
Commonwealth v. Barlowgreen
pasuperct · 2001 · cited in 5 Pennsylvania opinions naming this issue, 2002–2026
2 sentences

2026This Court, in Barlow, interpreted subsection 77.24(a) and concluded that “observation” does not require “eyes on [defendant’s] mouth 100% of the time[,]” Barlow, 776 A.2d at 275-76 .

2022We have held that compliance with the 20-minute rule goes “go to the trustworthiness of the evidence.” Commonwealth v. Barlow, 776 A.2d 273, 275 (Pa. Super. 2001).

15

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 (1)

CaseCitedYears
Commonwealth v. Little green
pa · 1986
2 sentences

1999Since the 1986 decision in Commonwealth v. Little, 354 Pa.Super. 546 , 512 A.2d 674 (1986), the Pennsylvania Code has been modified so as to require specifically that certification be done by a laboratory independent of the manufacturer. 11 .

1999Since the 1986 decision in Commonwealth v. Little, 354 Pa.Super. 546 , 512 A.2d 674 (1986), the Pennsylvania Code has been modified so as to require specifically that certification be done by a laboratory independent of the manufacturer. 11 .

11999–1999

Statutes the citing opinions construe

PA § 75 Pa. Cons. Stat. § 1547 (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

PA 6 (1999–2026) OH 5 (1993–2022) MO 5 (1999–2002) MT 3 (1992–2001) IL 3 (2015–2019) TN 2 (1997–2014) ND 2 (1985–1988) FL 2 (2004–2006) TX 2 (2003–2003) OR 2 (2000–2006)

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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