Your client is arrested for DUI based on his performance on some of the standard "walk a straight line" field sobriety tests conducted by the arresting officer, including a horizontal gaze nystagmus test. At the hearing on your motion to quash, the officer testifies that yes, she was trained how to do the tests, but no, her training wasn't based on the field training manual used by the National Highway Traffic Safety Administration. That's not an uncommon response. And it's your opening to challenge the reliability of the results, Rachel J. Hess writes in the most recent ISBA Traffic Laws and Courts newsletter. "Defendant should argue that the field sobriety test results, particularly that of the HGN test, should be excluded because the officer was not properly trained in accordance with the [NHTSA's] standardized field training manual," she writes. Read her helpful primer.