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

• The Defendant was involved in a single-vehicle accident that resulted in the death of the vehicle's passenger. After the accident, the Defendant was transported to a medical center where he admitted to consuming alcohol and marijuana prior to driving. A blood-alcohol test was conducted by an Emergency Medical Technician (EMT) at the medical center, which the Defendant sought to exclude from evidence on the basis that the EMT was not authorized to draw blood under the relevant statute (paras 2-3).

Procedural History

• District Court of San Juan County: The court granted the Defendant's motion to suppress the blood test results, agreeing with the Defendant that the EMT who drew the blood was not authorized under the statute to do so (para 4).

Parties' Submissions

• Defendant: Argued that the blood test results should be excluded because the individual who drew the blood, an EMT, was not among the categories of individuals authorized to perform such a task under the relevant statute (para 3).
• State: Contended that the EMT's training and experience working at the Medical Center qualified him as a laboratory technician or technologist employed by a hospital or physician, and thus was authorized to draw blood under the statute (para 3).

Legal Issues

• Whether the district court erred in excluding the blood test results on the basis that the EMT who drew the blood was not authorized under the relevant statute to do so (paras 1, 3-4).

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 its opinion (para 11).

Reasons

• Per LINDA M. VANZI, J. (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 referenced State v. Adams, which clarified that EMTs could be authorized to draw blood under certain circumstances, contrary to the district court's interpretation of State v. Garcia. The court determined that the EMT in question, due to his training and experience, as well as the context in which the blood draw occurred, qualified as a "laboratory technician" under the statute. The court emphasized that the Legislature intended for individuals with the EMT's skills and experience to fall within the category of "laboratory technician" for the purposes of the statute. The decision was based on the EMT's undisputed testimony regarding his qualifications and the procedures for legal blood draws (paras 5-10).