As U.S. Supreme Court Justice Alito noted in Birchfield v. North Dakota, “[d]runk drivers take a grisly toll on the Nation’s roads, claiming thousands of lives, injuring many more victims, and inflicting billions of dollars in property damage every year.” Justice Alito also states that proving that someone is driving under the influence (DUI) “requires a test, and many drivers stopped on suspicion of drunk driving would not submit to testing if given the option.” Because tougher DUI laws typically require jail time in the event of a conviction, it has become commonplace for DUI offenders to refuse chemical testing, even though the administrative penalty for doing so means they will likely lose their driving privileges for a period of time. Faced with an increasing number of refusals, some states have made it a crime for motorists to refuse DUI testing, including Kansas, Minnesota, and North Dakota. In Birchfield, the court considered whether such criminal refusal laws violated people’s rights under the Fourth Amendment.