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← 561 So. 2d 883 - State v. Armstrong

561 So. 2d 883 - State v. Armstrong’s Empirical Analysis

1990

Citation profile

38
cited by 38 later decisions
20
states following
June 2012
most recently cited

1 district · 36 state decisions

How this case has been cited

Cited by 38 later decisions — most recently June 2012 · most notably 8 Cal. 4th 587 - People v. Leahy (1994), State v. Baue (2000)

1 district · 36 state decisions — followed in 20 states

250199020002010decided

Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.

Relationships

Relies on Jackson v. Virginia · Frye v. United States · State v. Superior Court · 443 So. 2d 1098 - State v. Trosclair · Minnesota Public Interest Research Group v. Selective Service System

Most-quoted passages

The sentences later courts lift from this opinion, ranked by how many decisions quote each — the parts of the opinion doing the work. These counts are smaller than the citation total above because most of the 38 citing decisions cite the case generally; a passage count includes only decisions quoting that exact language verbatim.

  1. “The evidence demonstrates that the following propositions have gained general acceptance in the relevant scientific community: (1) HGN occurs in conjunction with alcohol consumption; (2) its onset and distinctness are correlated to BAC [blood-alcohol content]; (3) BAC in excess of.10 percent can be estimated with reasonable accuracy from the combination of the eye's tracking ability, the angle of onset of nystagmus and the degree of nystagmus at maximum deviation; and (4) officers can be trained to observe these phenomena sufficiently to estimate accurately whether BAC is above or below.10 percent.”
    1 later decision quote this exact passage
  2. “We choose to follow the reasoning in State v. Superior Court, County of Cochise, supra, that the HGN test meets the standards of admissibility in Frye and, with a proper foundation, may be admitted as evidence of intoxication. We also follow the reasoning of ... Superior Court ... and its progeny, in finding that a proper foundation for admitting the test has been laid when, a showing has been made that the officer ... was trained in the procedure, was certified in its administration and that the prvcedure was properly administered. [Emphasis added.]”
    1 later decision quote this exact passage
  3. “when a showing has been made that the officer who administered the test was trained in the procedure, was certified in its administration and that the procedure was properly administered.”
    1 later decision quote this exact passage

How this case has been treated — in progress

Whether each later court followed, distinguished, criticized, or overruled this decision. The treatment classification (task #35) runs highest-cited cases first and lights up here as it reaches this one.