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Keywords

due process

testimonydue process

Related Cases

People v. Haeussler, 41 Cal.2d 252, 260 P.2d 8

Facts

The case arose from a car accident involving Marion Joan Haeussler, who was driving a Buick convertible that collided with a Mercury sedan, resulting in the death of one passenger and injuries to others. The accident occurred late at night on a two-lane highway, where Haeussler's vehicle was observed in the wrong lane. After the accident, while Haeussler was unconscious, a medical attendant withdrew blood from her for testing, which later revealed a high alcohol content. Haeussler was subsequently charged with manslaughter and driving under the influence.

At about 1:00 a. m., a Buick convertible automobile operated by Mrs. Haeussler collided with a Mercury sedan driven by Vernon Lovelace in which Edward Amsel and Wayne Goff were riding.

Issue

Did the admission of the blood test results, taken without Haeussler's consent while she was unconscious, violate her due process rights?

As grounds for a reversal of the judgment, Mrs. Haeussler claims that the admission of testimony concerning the results of the blood test taken without her consent deprived her of due process of law.

Rule

The court held that evidence obtained through non-brutal means, even if taken without consent, does not necessarily violate due process rights, provided it does not shock the conscience.

The essence of the Rochin decision is in the court's reference to Brown v. State of Mississippi, 297 U.S. 278, 56 S.Ct. 461, 80 L.Ed. 682, and other coerced confession cases.

Analysis

The court analyzed the circumstances under which the blood was drawn, noting that it was taken for medical purposes while Haeussler was unconscious and that the procedure did not involve any brutal or shocking force. The court distinguished this case from Rochin v. California, where evidence was obtained through coercive means. The court concluded that the blood test was a medically approved procedure and did not constitute a violation of due process.

The court in the Rochin case approved prior decisions which declare that due process, as that term is used in the Fourteenth Amendment, does not embody all of the rights enumerated in the first eight amendments, but only those immunities which are ‘so rooted in the traditions and conscience of our people as to be ranked as fundamental’ or are ‘implicit in the concept of ordered liberty’.

Conclusion

The Supreme Court affirmed the judgment, concluding that the manner in which the blood sample was obtained did not violate Haeussler's due process rights.

Judgment affirmed.

Who won?

The People (State of California) prevailed in the case because the court found that the blood test evidence was admissible and did not violate due process.

Carter and Schauer, JJ., dissented.

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