Idaho v. Rios
Annotate this CaseRespondent Kyle Rios was involved in a car accident in Lewiston. After the accident, Rios was arrested and taken to a nearby hospital by Officer Williams. At the hospital, Rios declined to sign a consent form for a blood draw. Without obtaining a warrant, Officer Williams directed hospital staff to draw Rios’ blood for a blood alcohol test. Rios did not verbally or physically resist. Based in part on the results of the blood alcohol test, Rios was charged with felony vehicular manslaughter and felony leaving the scene of the accident. Rios filed a motion to suppress the results of the blood alcohol test, alleging the results were obtained through an unlawful search and seizure. The district court granted Rios’ motion, concluding Rios withdrew implied consent to the blood draw by declining to sign the consent form. The State appealed. The Supreme Court reversed, finding that the State seemed to argue Rios renewed his consent by voluntarily presenting his arm to the phlebotomist and failing to verbally or physically resisting the blood draw. "These actions show only that Rios complied with the officer’s orders. Compliance with an officer’s orders alone does not renew consent." The Court held that Rios revoked implied consent by declining to sign the consent form, and therefore upheld the district court’s order suppressing the results of the blood alcohol test.
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