If your client refuses a breath/blood/urine test the state may argue consciousness of guilt. Your defense must include an explanation as to how and why the refusal occurred.  Often the client voluntarily complied with the pre-arrest field sobriety tests.  Question the officer as to your clients cooperation of all of the other tests he took prior to being handcuffed and arrested. At this stage, your client felt enough was enough and no longer complied with that officer.