The alphabet and counting exercises are verbal divided-attention tasks. The officer typically asks you to recite a portion of the alphabet, often from one letter to another and without singing it, or to count backward between two numbers. The officer listens for missed or repeated letters, restarts, and slurred speech. Neither is a standardized exercise, so they come in only as the officer’s lay observations rather than as a scientific test, a point covered in the field sobriety overview.
The theory is that alcohol hurts the ability to do two things at once, here remembering a sequence while speaking it. The problem is that these tasks were never validated as roadside tests, and a related approach using serial recitation did not hold up in the research. There is no official scoring, so the officer grades by ear.
Reciting part of the alphabet or counting backward leans on education and composure as much as anything to do with alcohol, and it has no validation as a roadside test.
It tests schooling and nerves more than alcohol
Reciting the alphabet from an odd starting letter to an odd ending letter, without singing, is harder than it sounds, because many folks learned the alphabet as a song and never recite fragments of it. Counting backward is the same. Performance turns on education, literacy, language background, and composure, and being put on the spot by an officer at the roadside rattles sober people. A stumble there is weak evidence of impairment.
Put plainly, reciting letters and numbers on command measures how you were schooled and how your voice holds up under fear far more than it measures sobriety. A person who learned English as a second language, who has a stutter, who never finished school, or who simply has not said the alphabet out loud since childhood can trip over it completely sober, and adding pressure, a badge, and flashing lights ties anyone’s tongue. There is no standard for how fast or how cleanly it has to be done and no validated scoring, so the officer is left grading an accent, an education, and a case of nerves and calling the result impairment. Even NHTSA’s own research set these recitation tasks aside, which is why they never made the standardized battery.
No standard, no score
Because there is no validated procedure, officers give these tasks differently and judge them differently. One officer’s confusing instruction is another’s clear one, and a single restart might be called a clue or ignored. In your case I show the jury that a brief verbal task with no scientific scoring, judged by the officer who already suspected you, does not prove you were impaired.
The law treats this as a lay observation, not a test
Florida law puts the alphabet and counting tasks in the same category as the other psychomotor exercises, which means it treats them as ordinary observations rather than science. The lay-versus-science line for the whole battery is set out in the field sobriety overview. So an officer can tell the jury what he heard, but the State should not be permitted to call this a test you failed or to suggest you scored points, because the alphabet and counting tasks were never validated and carry no scoring at all. I ask the court to keep that misleading language out by motion in limine.
There is also a fairness problem the jury can see once it is pointed out. Reciting letters from an odd starting point without singing, or counting down between two numbers chosen on the spot, draws on memory and language as much as anything to do with alcohol. Education, literacy, a first language other than English, a hearing problem, and plain nerves each change the result, and the officer almost never asks about any of them before deciding you did poorly. As an NHTSA field sobriety instructor I can walk the jury through what the standardized battery requires and show that these verbal tasks were not part of it, which leaves the State leaning on a roadside quiz that proves very little.
I have watched officers treat a stumble over the alphabet as if it decided the case, and it decides nothing. I put the jury in your shoes, scared, on the side of a road, being asked to perform a grade-school drill for a stranger with a light in your face. There is no manual and no score behind this one, and the government’s own researchers dropped it, so I will not let how you were educated or how your voice shook be turned into evidence that you were drunk.
I started out as an Assistant Public Defender in Florida’s Thirteenth Judicial Circuit, in Tampa, and today I am one of six ACS-CHAL Forensic Lawyer-Scientists in Florida and an NHTSA-qualified field sobriety instructor. I was trained to administer this battery and to teach the officers who give it, so I can stand in front of a jury and show the exact point where the roadside exercises in your case left the standard. Learn more about my background.
Questions About Alphabet and Counting
What is the alphabet test?
The officer usually asks you to recite a part of the alphabet, for example from one letter to another, without singing it, or to count backward between two numbers. The officer listens for errors, restarts, and slurred speech.
Is reciting the alphabet a standardized test?
No. It is not one of the three NHTSA validated exercises. There is no validation study and no official scoring, and a related serial-task approach did not hold up in the research as a reliable indicator.
What does it really measure?
Education, literacy, language background, and composure under pressure as much as anything else. Being asked to start and stop at odd letters, without singing, is confusing for many sober people, especially when nervous.
Does Florida allow it?
It can come in only as the officer's lay observation of how you spoke and performed, not as a scientific test with a pass-fail line, because these tasks were never validated and carry no scoring.
How do you challenge it?
I show the jury the task has no validation, that an unusual instruction heard once at a roadside trips up sober people, and that schooling, language, and nerves explain a stumble far better than alcohol.
Related: the non-standardized overview, the finger count, how clues are scored, the roadside conditions, and the field sobriety overview.
I messed up the alphabet. Does that prove I was drunk?
No. This exercise turns on schooling, first language, and nerves far more than alcohol, and there is no validated scoring for it. People who learned English as a second language, who are anxious, or who rarely say the alphabet as adults stumble while completely sober, and NHTSA’s own research set these tasks aside.
This page is general information, not legal advice, and it does not create an attorney-client relationship. Field sobriety exercises in Florida are governed by case law and by section 316.193, Florida Statutes. Procedures and rules change, and every case turns on its own facts. Past results do not guarantee a similar outcome.
