failed alphabet test in Delaware

2023“In the specific context of DUI arrests, probable cause is generally based on the arresting officer’s observations of the arrestee, which may include field sobriety tests.” Id. at 671 . 8 See, e.g., Bease v. State, 884 A.2d 495 , 499–500 (Del. 2005) (holding that evidence of a traffic violation, odor of alcohol, rapid speech, admission to drinking, bloodshot and glassy eyes, and a failed alphabet test constituted probable cause to arrest the driver for a DUI offense); see also Rybicki v. State, 119 A.3d at 671 (observing that refusal to submit to field sobriety tests, breath 5 (12) Similarly,

2017Lefebvre, 19 A.3d at 292-93 (probable cause to arrest driver for DUI without any field sobriety tests, Where driver committed a traffic offense, exhibited a strong odor of alcohol, had a flushed face, admitted drinking, and Was somewhat flustered and argumentative with the officer); Bease v. State, 884 A.2d 495,498 (Del. 2005) (evidence of a traffic violation, odor of alcohol, rapid speech, admission to drinking, bloodshot and glassy eyes and a failed alphabet test constituted probable to arrest the driver for DUI); Maxwell, 624 A.2d at 929-31 (Probable cause to believe defendant violated DUI

2020State, 19 A.3d 287, 292-293 (Del. 2011). 12 See Rybicki v. State, 119 A. 3d at 671 (citations omitted). 4 probable cause does exist when a traffic violation and odor of alcohol ate accompanied by “rapid speech, admission to drinking, bloodshot and glassy eyes and a failed alphabet test.””!

2017Lefebvre, 19 A.3d at 292-93 (probable cause to arrest driver for DUI without any field sobriety tests, Where driver committed a traffic offense, exhibited a strong odor of alcohol, had a flushed face, admitted drinking, and Was somewhat flustered and argumentative with the officer); Bease v. State, 884 A.2d 495,498 (Del. 2005) (evidence of a traffic violation, odor of alcohol, rapid speech, admission to drinking, bloodshot and glassy eyes and a failed alphabet test constituted probable to arrest the driver for DUI); Maxwell, 624 A.2d at 929-31 (Probable cause to believe defendant violated DUI

2023“In the specific context of DUI arrests, probable cause is generally based on the arresting officer’s observations of the arrestee, which may include field sobriety tests.” Id. at 671 . 8 See, e.g., Bease v. State, 884 A.2d 495 , 499–500 (Del. 2005) (holding that evidence of a traffic violation, odor of alcohol, rapid speech, admission to drinking, bloodshot and glassy eyes, and a failed alphabet test constituted probable cause to arrest the driver for a DUI offense); see also Rybicki v. State, 119 A.3d at 671 (observing that refusal to submit to field sobriety tests, breath 5 (12) Similarly,

2023“In the specific context of DUI arrests, probable cause is generally based on the arresting officer’s observations of the arrestee, which may include field sobriety tests.” Id. at 671 . 8 See, e.g., Bease v. State, 884 A.2d 495 , 499–500 (Del. 2005) (holding that evidence of a traffic violation, odor of alcohol, rapid speech, admission to drinking, bloodshot and glassy eyes, and a failed alphabet test constituted probable cause to arrest the driver for a DUI offense); see also Rybicki v. State, 119 A.3d at 671 (observing that refusal to submit to field sobriety tests, breath 5 (12) Similarly,

2017Lefebvre, 19 A.3d at 292-93 (probable cause to arrest driver for DUI without any field sobriety tests, Where driver committed a traffic offense, exhibited a strong odor of alcohol, had a flushed face, admitted drinking, and Was somewhat flustered and argumentative with the officer); Bease v. State, 884 A.2d 495,498 (Del. 2005) (evidence of a traffic violation, odor of alcohol, rapid speech, admission to drinking, bloodshot and glassy eyes and a failed alphabet test constituted probable to arrest the driver for DUI); Maxwell, 624 A.2d at 929-31 (Probable cause to believe defendant violated DUI

2016See also Bease v. State, 884 A.2d 495, 498-99 (Del. 2005) (holding that a traffic violation, the smell of alcohol on the defendant’s breath, his rapid speech, his bloodshot and glassy eyes, and his admission to drinking alcohol the night before were sufficient to find probable cause); State v. Maxwell, 624 A.2d 926, 930 (Del. 1993) (holding that the occurrence of a one car collision, witness statements that the defendant told them he had been drinking and that he seems dazed, the presence of empty and full beer cans in the vehicle, and the strong smell of alcohol in the vehicle were sufficient

2017See also Charch v. State, 11 A.3d 226 , at n. 11 (Del. 2010) (“[A] defendant’s refusal to submit to testing can be used for any relevant purpose, including showing consciousness of guilt” in DUI case); State v. Trager, 2006 WL 2194764 , at *6 (Del.