TROPPMAN v. VALVERDE
Vehicle Code Sec. 23612's implied consent law, which deems motorists who have been lawfully arrested for driving while under the influence to have consented to chemical testing, does not require proof of actual driving immediately prior to lawful arrest for driving while under the influence of alcohol or a drug. Revocation or suspension of a license under Sec. 13353 and related statutes for refusal to submit to chemical testing under implied consent law does not require proof that the person actually was driving immediately prior to the arrest.
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