United States v. Blakeney, No. 18-4921 (4th Cir. 2020)Annotate this Case
The Fourth Circuit affirmed the district court's denial of defendant's motions to suppress evidence of a toxicology analysis of blood drawn from defendant just after a car accident, and a review of defendant's car's event data recorder. Defendant was convicted of vehicular homicide while impaired by alcohol.
The court agreed with the district court that the warrant applications established probable cause and that the search warrants were sufficiently particularized. In any event, the court held that suppression would be inappropriate under United States v. Leon, 468 U.S. 897 (1984), because the officers relied in objective good faith on the search warrants to obtain the evidence in question.