Whitlow v. Commonwealth

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Justia Opinion Summary

The Supreme Court affirmed the ruling of the trial court denying Defendant's motion to suppress blood test results obtained via a court order directing the hospital at which Defendant was treated after an accident to test Defendant's blood for drugs and alcohol, holding that the trial court properly denied Defendant's motion to suppress.

Defendant was driving while intoxicated when she struck and killed two pedestrians standing on a sidewalk. After Defendant was transported to the hospital to be treated for minor injuries, the hospital tested Defendant's blood. In her motion to suppress Defendant argued that the testing violated her Fourth Amendment rights because the court order was not a search warrant. The trial court denied the motion, and Defendant pled guilty to second-degree manslaughter. The Supreme Court affirmed, holding that the court order was for all intents and purposes a valid search warrant and that no violations of Defendant's Fourth Amendment rights occurred.

Primary Holding

The Supreme Court affirmed the ruling of the trial court denying Defendant's motion to suppress blood test results obtained via a court order directing the hospital at which Defendant was treated after an accident to test Defendant's blood for drugs and alcohol, holding that the trial court properly denied Defendant's motion to suppress.

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