Colorado v. HydeAnnotate this Case
Defendant Oliver Hyde was involved in a single-vehicle accident that left him unconscious. The police suspected that he might have been driving under the influence of alcohol. Hyde was transported to the hospital, and, in accordance with Colorado law, a sample of his blood was taken to establish his blood-alcohol concentration. Hyde was charged with driving under the influence of alcohol (DUI). He sought to have the result of the blood test suppressed as evidence obtained through an illegal search in violation of the Fourth Amendment to the United States Constitution. The trial court granted his motion to suppress, and the State filed an interlocutory appeal. After review, the Colorado Supreme Court found that by driving in Colorado, Hyde consented to the terms of the Expressed Consent Statute, including its requirement that he submit to blood-alcohol testing under the circumstances present here. Hyde’s statutory consent satisfied the consent exception to the Fourth Amendment warrant requirement. The Court therefore concluded that in the circumstances presented here, the blood draw was constitutional.