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Keywords

willmisdemeanor

Related Cases

Birchfield v. North Dakota, 579 U.S. 438, 136 S.Ct. 2160, 195 L.Ed.2d 560, 84 USLW 4493, 14 Cal. Daily Op. Serv. 6499, 2016 Daily Journal D.A.R. 6086, 26 Fla. L. Weekly Fed. S 300

Facts

The case involved three petitioners arrested for drunk driving in North Dakota and Minnesota. Danny Birchfield was charged with misdemeanor refusal to submit to a blood test after being informed that refusal could lead to criminal penalties. William Robert Bernard, Jr. was charged with first-degree test refusal after refusing a breath test, while Steve Michael Beylund consented to a blood test but later argued that his consent was coerced. The cases were consolidated for argument before the Supreme Court.

To fight the serious harms inflicted by drunk drivers, all States have laws that prohibit motorists from driving with a blood alcohol concentration (BAC) exceeding a specified level. BAC is typically determined through a direct analysis of a blood sample or by using a machine to measure the amount of alcohol in a person's breath.

Issue

Whether the Fourth Amendment permits warrantless breath tests and blood tests incident to arrests for drunk driving, and whether motorists can be criminally punished for refusing to submit to a blood test based on implied consent.

The question presented is whether such laws violate the Fourth Amendment's prohibition against unreasonable searches.

Rule

The Fourth Amendment allows warrantless breath tests incident to arrests for drunk driving but does not permit warrantless blood tests. Additionally, motorists cannot be criminally punished for refusing to submit to a blood test based on implied consent.

The Fourth Amendment permits warrantless breath tests incident to arrests for drunk driving but not warrantless blood tests.

Analysis

The Court analyzed the privacy implications of breath and blood tests, concluding that breath tests are less intrusive and serve a significant governmental interest in public safety. In contrast, blood tests are more invasive and require a warrant unless exigent circumstances exist. The Court emphasized that while implied consent laws can impose civil penalties, they cannot criminalize the refusal of a blood test.

Because the impact of breath tests on privacy is slight, and the need for BAC testing is great, the Fourth Amendment permits warrantless breath tests incident to arrests for drunk driving. Blood tests, however, are significantly more intrusive, and their reasonableness must be judged in light of the availability of the less invasive alternative of a breath test.

Conclusion

The Supreme Court affirmed that warrantless breath tests are permissible, but warrantless blood tests are not. It also ruled that criminal penalties for refusing a blood test based on implied consent are unconstitutional.

Motorists may not be criminally punished for refusing to submit to a blood test based on legally implied consent to submit to them.

Who won?

The petitioners prevailed in part, as the Court ruled that criminal penalties for refusing a blood test are unconstitutional, while the state could still enforce breath tests without a warrant.

The Supreme Court, Justice Alito, held that: 1 the Fourth Amendment permits warrantless breath tests incident to arrests for drunk driving; 2 the Fourth Amendment does not permit warrantless blood tests incident to arrests for drunk driving; and 3 motorists cannot be deemed to have consented to submit to a blood test on pain of committing a criminal offense, abrogating State v. Smith, 849 N.W.2d 599.

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