Com. v. Michua-Garfias, C.
Com. v. Michua-Garfias, C. No. 1731 MDA 2016
| Pa. Super. Ct. | Sep 5, 2017Background
- Cristhian Michua-Garfias was stopped twice (Jan. 10 and Mar. 16, 2016) and arrested on suspicion of DUI; troopers transported him to the hospital both times for blood draws.
- At each hospital visit the officers read the DL-26 implied-consent form (late evening), and Michua-Garfias agreed to blood samples—blood drawn within minutes after the reading.
- Michua-Garfias moved to suppress the blood-test results at both dockets; the parties submitted stipulated facts instead of live testimony.
- The trial court granted the suppression motions, concluding Michua-Garfias’ consent to the blood draws was not voluntary under Birchfield v. North Dakota, and excluded the blood-test results.
- The Commonwealth appealed, conceding voluntariness was resolved under Birchfield but arguing this Court should apply a limited good-faith exception to the exclusionary rule to admit the blood results.
Issues
| Issue | Plaintiff's Argument (Commonwealth) | Defendant's Argument (Michua-Garfias) | Held |
|---|---|---|---|
| Whether a good-faith exception should allow admission of blood-test results despite involuntary consent under Birchfield | Officers reasonably relied on existing implied-consent law; exclusionary rule’s deterrence goal not served, so evidence should be admitted under a limited good-faith exception | Suppression required because consent was involuntary and Pennsylvania does not recognize a good-faith exception under Article I, Section 8 | The court refused to create a good-faith exception; affirmed suppression |
Key Cases Cited
- Birchfield v. North Dakota, 136 S. Ct. 2160 (U.S. 2016) (holding warrantless blood draws as searches implicate the Fourth Amendment and discussing voluntariness and test refusal consequences)
- United States v. Leon, 468 U.S. 897 (U.S. 1984) (established federal good-faith exception to the exclusionary rule for reliance on a magistrate-issued warrant)
- Commonwealth v. Edmunds, 586 A.2d 887 (Pa. 1991) (Pennsylvania Supreme Court rejected a good-faith exception to the state exclusionary rule under Article I, Section 8)
- Commonwealth v. Johnson, 86 A.3d 182 (Pa. 2014) (explains Leon and reaffirms that Pennsylvania law historically declines a good-faith exception under the state constitution)