Texas v. Villarreal (original by judge alcala)Annotate this Case
The issue this case presented for the Court of Criminal Appeals' review came as an interlocutory appeal by the State. The trial court granted appellee David Villarreal's motion to suppress blood evidence after his arrest for felony DWI and subjected to a warrantless blood-specimen collection. The State challenged the trial court’s and the court of appeals’s conclusion that the warrantless search of Villarreal’s blood under statutory authority providing for implied consent and mandatory blood-specimen collection violated the Fourth Amendment. In addressing the merits of the State’s challenge to the trial court’s ruling, the Court concluded that the warrantless, nonconsensual testing of a DWI suspect’s blood did not categorically fall within any recognized exception to the Fourth Amendment’s warrant requirement, nor could it be justified under a general Fourth Amendment balancing test. Accordingly, the Court of Criminal Appeals held that the search in this case violated the Fourth Amendment. With respect to the State’s specific complaints regarding the court of appeals’s analysis, although the court of appeals erred by determining that the State forfeited its implied-consent argument on appeal through stipulation, remand was unnecessary in light of both the court of appeals’s implicit rejection of that argument and the Court of Criminal Appeals' express rejection of that argument. Furthermore, the Court concluded that the court of appeals erred to address the constitutionality of the mandatory-blood-draw statute and, in light of the holding in this case, the Court declined to review the State’s complaint with respect to that matter.