Law School Case Brief
Missouri v. McNeely - 569 U.S. 141, 133 S. Ct. 1552 (2013)
The Fourth Amendment provides in part that the right of the people to be secure in their persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be violated, and no warrants shall issue, but upon probable cause. A warrantless search of the person is reasonable only if it falls within a recognized exception. That principle applies to taking involuntary blood samples, which involve a compelled physical intrusion beneath the subject’s skin and into his veins to obtain a sample of his blood for use as evidence in a criminal investigation. Such an invasion of bodily integrity implicates an individual’s most personal and deep-rooted expectations of privacy.
Defendant Tyler McNeely refused to consent to an alcohol breath test or a blood test after he was arrested for driving while intoxicated. The arresting patrolman, without seeking a warrant from a judge, ordered a medical professional to draw McNeely's blood. The blood sample was analyzed, and the results revealed that McNeely's blood-alcohol content was well above the legal limit. At trial in Missouri state court, McNeely filed a motion to suppress the results of the blood test. The trial court granted the motion, finding that the nonconsensual and warrantless blood draw was a violation of McNeely's Fourth Amendment rights. On interlocutory appeal, the state supreme court affirmed the trial court's decision, holding first that the dissipation of alcohol did not establish a per se exigency, and second that the State could not otherwise satisfy its burden of establishing exigent circumstances. The State was granted a writ of certiorari on the issue of whether dissipation of alcohol established a per se exigency.
Does the natural metabolization of alcohol in the bloodstream presented a per se exigency that justifies an exception to the Fourth Amendment’s warrant requirement for nonconsensual blood testing in all drunk-driving cases?
The Supreme Court of the United States affirmed the appellate court's decision. The Court held that while the natural dissipation of alcohol in the blood could support a finding of exigency in a specific case, it did not do so categorically. Whether a warrantless blood test of a drunk-driving suspect was reasonable had to be determined case by case based on the totality of the circumstances. Any compelled intrusion into the human body implicated significant, constitutionally protected privacy interests. The general importance of the interest in combating drunk driving did not justify departing from the warrant requirement without showing exigent circumstances that made securing a warrant impractical in a particular case. The Court observed that because the case was argued before it on the broad proposition that drunk-driving cases presented a per se exigency, the arguments and the record did not provide the Court with an adequate analytic framework for a detailed discussion of all the relevant factors that could be taken into account in determining the reasonableness of acting without a warrant.
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