Idaho v. Charlson
Annotate this CaseDefendant-appellant Kirk Charlson appealed after he was convicted for felony driving under the influence. Before the trial, Charlson filed a motion to suppress the results of an evidentiary blood draw that was conducted without a warrant. The district court denied the motion, and Charlson was convicted. On appeal of the denial of his motion to suppress the results of the evidentiary blood draw, Charlson argued the draw violated his Fourth Amendment rights. When the totality of the circumstances in this case were considered, the Supreme Court concluded the State established voluntary consent to evidentiary testing sufficient to obviate the need for a warrant to draw Charlson’s blood. Although the district court did not have the benefit of the Supreme Court’s recent relevant opinions, it nonetheless reached the correct result. Therefore, its order denying Charlson’s motion to suppress the evidence against him was affirmed.
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