State v. BlattermanAnnotate this Case
After receiving a complaint from Defendant’s wife, police officers conducted an investigatory stop of Defendant’s vehicle. Defendant did not comply with police orders after being stopped and also complained of chest pain. The police transported Defendant to a hospital for medical assessment and then conducted a legal blood draw. Results of the blood test demonstrated that Defendant had operated his vehicle with a prohibited alcohol concentration (PAC). Defendant was subsequently charged with operating while intoxication (OWI) and with a PAC. The circuit court denied Defendant’s motion to suppress the blood test results. The court of appeals reversed, concluding that Defendant’s transportation to the hospital exceeded the scope of the investigatory detention and violated Defendant’s Fourth Amendment rights. The Supreme Court reversed, holding (1) Defendant’s stop and detention satisfied the reasonableness requirement of the Fourth Amendment because they were supported by reasonable suspicion to conduct an investigatory detention; (2) Defendant’s arrest when he was transported to the hospital was constitutional because the officers had probable cause to arrest Defendant; and (3) the transportation to the hospital was lawful as a community caretaker function of law enforcement.