State v. WeddleAnnotate this Case
The Supreme Judicial Court affirmed the judgment of conviction entered by the trial court as a result of a jury verdict finding Defendant guilty of two counts of manslaughter, two counts of causing a death while operating under the influence, and related charges, holding that the court did not err when it denied Defendant's motion to suppress the results of a warrantless blood draw taken at the scene of a fatal motor vehicle accident.
Me. Rev. Stat. 29-A, 2522(2) directs law enforcement officers to test the blood of all drivers involved in a fatal, or likely fatal, motor vehicle accident without any requirement of probable cause before the blood draw. Defendant argued on appeal that the statute is unconstitutional on its face. The Supreme Judicial Court agreed but nonetheless affirmed the trial court's denial of Defendant's motion to suppress, holding (1) Me. Rev. Stat. 29-A, 2522(2) violates the Fourth Amendment because it does not require that law enforcement have consent or probable cause to believe that a driver is impaired before drawing a person's blood; but (2) the trial court correctly denied Defendant's motion to suppress because the "good faith" exception to the exclusionary rule applied to the search.