United States v. Manubolu, No. 20-1871 (1st Cir. 2021)
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The First Circuit reversed the ruling of the district court suppressing blood alcohol content evidence from a warrantless blood draw because no exigent circumstances were present, holding that the district court misapplied the law to the facts in this case.
After a car accident that killed three people, a police officer ordered a warrantless blood of Defendant's blood without Defendant's consent and without exigent circumstances. The government charged Defendant with three counts of manslaughter and other intoxicated-driving crimes. Defendant filed a motion to suppress evidence from the warrantless blood draw, which the district court granted. The First Circuit reversed, holding that the government met its burden to show it was reasonable for the police officer to think exigent circumstances existed when he took the blood draw.
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