AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

• Plaintiff was stopped at a DWI checkpoint, exhibited signs of intoxication but denied drinking that day. After failing field sobriety tests, she was arrested for DWI. Breathalyzer tests showed a .000 BrAC, yet Defendant ordered a blood test, which also tested negative for alcohol and drugs. The DWI charge was later dismissed (paras 2-3).

Procedural History

• District Court of Colfax County: Granted Defendant's motion for summary judgment, dismissing Plaintiff's civil rights claims with prejudice (para 1).

Parties' Submissions

• Plaintiff: Argued that Defendant violated her Fourth Amendment rights by arresting and detaining her after breath tests showed no alcohol, failing to release her, and subjecting her to a warrantless blood test without exigent circumstances (para 6).
• Defendant: Contended he is entitled to qualified immunity, arguing there was probable cause for Plaintiff's arrest based on her performance on the SFSTs and observations. Defendant later argued Plaintiff consented to the blood draw, rendering it constitutional (paras 5, 7).

Legal Issues

• Whether Defendant had probable cause to arrest Plaintiff for DWI after she blew a .000 on two breath tests (para 8).
• Whether Defendant's failure to release Plaintiff following the breath tests violated clearly established law (para 14).
• Whether Defendant violated Plaintiff's Fourth Amendment rights by subjecting her to a warrantless blood test without exigent circumstances (para 19).

Disposition

• Affirmed in part: The court affirmed the district court's grant of summary judgment to Defendant on Plaintiff's unlawful arrest claim.
• Reversed in part: The court reversed the district court's grant of summary judgment to Defendant on Plaintiff's unreasonable seizure claim based on the warrantless blood draw and remanded for further proceedings (para 34).

Reasons

• The court found that Defendant had probable cause to arrest Plaintiff based on her performance on the SFSTs and other observations prior to the breathalyzer tests. However, it held that probable cause to suspect intoxication from alcohol did not automatically dispel probable cause for driving under the influence of drugs. The court concluded that Plaintiff failed to show that Defendant's failure to release her following the breath tests violated a clearly established right. Regarding the warrantless blood draw, the court determined that Defendant failed to establish Plaintiff's consent and that the warrantless blood draw violated a clearly established right, as exigent circumstances were not present. The court relied on precedent and statutory analysis to conclude that Defendant was not entitled to qualified immunity for the warrantless blood draw claim (paras 10-33).