Does the State Have to Prove That Test Results of Urine Samples Are Not Affected by Prescribed Medication As An Element of Its Case ?

In People v. Bishop, 354 Ill. App. 3d 549, 821 N.E.2d 677 (2004), the defendant was involved in an automobile accident. The defendant's conviction was based upon a hospital urine sample that showed cocaine and PCP in his system. Bishop, 2004 Ill. App. The defendant appealed, arguing that medicine administered by the hospital rendered his urine test inaccurate. Bishop, 2004 Ill. App. Relying on People v. Winfield, 30 Ill. App. 3d 668, 672, 332 N.E.2d 634 (1975), the Bishop court concluded that the State is not required to prove that prescribed medications did not affect the accuracy of test results, unless there is some evidence in the record to the contrary. Bishop, 2004 Ill. App. Specifically, the Bishop court stated: "To the extent that Miller goes beyond the holding in Winfield and suggests that the State must prove that any prescribed medication did not affect the test results as an element of its case, we disagree with such a requirement and we note that Miller cites no authority to support its conclusion. Here, there was simply no evidence that the medications given to defendant had any affect on the results of his urine sample, and in the absence of such evidence, the State was not required to prove that results were not affected by the medications." Bishop, 2004 Ill. App.