Pennsylvania v. Wolfel (majority)
Annotate this CaseWhile driving a vehicle in December 2014, Appellant Kaitlyn Wolfel struck two pedestrians, killing one and injuring the other. She was arrested on suspicion of driving under the influence, and police transported her to a local health center for blood testing. Prior to the blood draw, police advised Appellant that, if she refused to submit to the test, she would be subject to enhanced criminal penalties pursuant to the Implied Consent Law. Appellant consented to the procedure, and the test yielded a blood alcohol content of .178 percent. Appellant was charged with numerous criminal offenses, including homicide by vehicle while driving under the influence. In 2016, while the case remained at the pretrial stage, the federal Supreme Court issued its decision in Birchfield v. North Dakota, 136 S. Ct. 2160 (2016). Birchfield held, among other things, that consent to a warrantless blood draw was vitiated when such assent follows the administration by police of a warning of enhanced criminal penalties upon refusal of the testing. Appellant then lodged a motion contending, in very general terms, that Birchfield required suppression of the blood evidence. The Pennsylvania Supreme Court determined the Commonwealth waived its challenge to Appellant’s failure to raise a claim under Pa. Const. Article I, Section 8, by failing to challenge the suppression court’s explicit invocation of that provision before the superior court. The superior court order was reversed and the matter remanded for further proceedings.
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