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    THE HEEL-TO-TOE TEST

    This is one of the “big three” standardized field sobriety tests that cops are taught to perform in each and every drunk driving investigation.  This particular test requires you to walk in a straight line for nine steps, pivot, then walk nine steps back.

    HOW TO PERFORM THE TEST

    In the Heel-To-Toe test, the subject is directed to take nine steps, heel-to-toe, along a straight line. After taking the steps, the suspect must turn on one foot and return in the same manner in the opposite direction.  The cops is supposed to look for eight indicators of impairment: if the suspect cannot keep balance while listening to the instructions, begins before the instructions are finished, stops while walking to regain balance, does not touch heel-to-toe, steps off the line, uses arms to balance, makes an improper turn, or takes an incorrect number of steps. 

    HOW COPS TYPICALLY PERFORM THE TEST

    The test itself is very easy for the cops to instruct, however, it is very hard for the officers to remember what they are supposed to be looking for.  This creates great fodder during trial as I have had many cops admit that although they indicated my clients failed the test, in fact, after reviewing what they were actually supposed to be looking for, they passed the test

    EXAMPLE OF HEEL-TO-TOE CROSS EXAMINATION