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Fields v. State

Citations: 811 N.E.2d 978; 2004 Ind. App. LEXIS 1389; 2004 WL 1614888Docket: No. 73A01-0306-CR-230

Court: Indiana Court of Appeals; July 20, 2004; Indiana; State Appellate Court

Narrative Opinion Summary

Steven Fields' petition for rehearing concerning the case Fields v. State is addressed, affirming the original opinion while clarifying the burden of proof regarding the twenty-minute deprivation period before a chemical breath test. The court reaffirmed that the State adequately demonstrated proper administration of the test, as Deputy Lacy instructed Fields to remove chewing tobacco and waited the requisite twenty minutes before conducting the test. Fields contended that the ruling improperly shifted the burden onto him to prove that any residual tobacco affected the test results. However, the court clarified that once the State proved adherence to the proper procedure, the burden shifted to Fields to challenge that evidence, which he failed to do. Consequently, the court upheld its original decision, with Judge Baker concurring and Judge Riley dissenting regarding the petition's denial.

Legal Issues Addressed

Burden of Proof in Chemical Breath Test Administration

Application: The court clarified that after the State demonstrates proper administration of a chemical breath test, the burden shifts to the defendant to challenge the validity of that procedure.

Reasoning: The court clarified that once the State proved adherence to the proper procedure, the burden shifted to Fields to challenge that evidence, which he failed to do.

Defendant's Responsibility to Prove Test Result Impact

Application: Once the State has shown proper test administration, the defendant is responsible for proving any factors that may have impacted the test results, such as residual substances.

Reasoning: Fields contended that the ruling improperly shifted the burden onto him to prove that any residual tobacco affected the test results.

Proper Administration of Chemical Breath Test

Application: The State must demonstrate that the chemical breath test was administered correctly, including ensuring a twenty-minute deprivation period before the test.

Reasoning: The court reaffirmed that the State adequately demonstrated proper administration of the test, as Deputy Lacy instructed Fields to remove chewing tobacco and waited the requisite twenty minutes before conducting the test.