AI Generated Opinion Summaries

Decision Information

Decision Content

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Facts

  • After being arrested for DUI, the arresting officer obtained a warrant for a blood sample from the Defendant, which was drawn at a medical center by an employee not explicitly authorized under the relevant statute to perform such a task. The Defendant was charged with aggravated DUI and moved to suppress the blood test results, arguing the employee was not authorized to draw blood under the statute.

Procedural History

  • District Court of San Juan County, Karen L. Townsend, District Judge: The court ordered the exclusion of the blood draw test results on the grounds that the blood drawer was not authorized under the Implied Consent Act.

Parties' Submissions

  • Plaintiff-Appellant (State): Argued that the employee who drew the Defendant's blood was qualified to do so based on her training and experience, despite not being explicitly listed as authorized under the statute.
  • Defendant-Appellee (Garcia): Contended that the blood test results should be suppressed because the employee who drew the blood did not fall under the categories of individuals authorized by the statute to perform a blood-alcohol test.

Legal Issues

  • Whether the district court erred in excluding blood test results based on the interpretation that the employee who drew the blood was not authorized under the Implied Consent Act.

Disposition

  • The Court of Appeals reversed the district court’s order excluding the Defendant’s blood test results and remanded for further proceedings consistent with this opinion.

Reasons

  • Per Linda M. Vanzi, J. (with J. Miles Hanisee, J., and Jacqueline R. Medina, J., concurring): The Court of Appeals found that the district court abused its discretion by excluding the blood test results based on a misapprehension of the law. The court clarified that the employee, despite being licensed as an EMT and not explicitly listed under the statute, was qualified to draw blood under the broader interpretation of "laboratory technician" as intended by the Legislature. This conclusion was supported by the employee's training, experience, and the duties assigned by the medical center, distinguishing the case from previous jurisprudence and aligning with the reasoning in State v. Adams, which addressed similar issues (paras 1-12).
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