People v. Toran

In People v. Toran, 219 Ill. App. 3d 991, 580 N.E.2d 595, 162 Ill. Dec. 632 (Ill. App., 2nd Dist. 1991), an Illinois Court of Appeals addressed a claim that a probationer's confession of cocaine use was involuntary. The court held that admission of the confession, if error, was harmless because of positive drug test results. Id. at 598-599. The defendant's urine was tested (in 1989) by two different methods: (1) the ADx analyzer and; (2) the Toxi-Lab thin layer chromatography test; both tests indicated the presence of cocaine. Id. at 597. According to the Illinois court, "Testimony was presented that both testing methods were generally accepted as reliable within the chemistry field." Id So, as early as 1989, the ADx analyzer was in use, and there was testimony at that time that tests conducted by the machine were generally accepted as reliable, at least as to cocaine. It is questionable, however, whether such testimony establishes the test's reliability for determining the presence of marijuana.