Joseph E. Haselden v. State of Indiana (mem. dec.)
32A01-1705-CR-1141
| Ind. Ct. App. | Oct 20, 2017Background
- Around 2:00 a.m. on July 1, 2014, police found Joseph Haselden unconscious in a crashed, rolled vehicle; he was disoriented, had blood on his face, dilated pupils, and slurred/lethargic speech.
- Officer Marcum suspected intoxication, transported Haselden to a hospital, and applied for a search warrant for a blood draw using a pre-printed affidavit form (one box was checked in error).
- The warrant issued about 90 minutes after the crash; blood drawn around 4:15 a.m. later tested .18% BAC and positive for benzodiazepines and opiates.
- Haselden was charged with operating while intoxicated and with an alcohol concentration of .15 or greater; he moved to suppress the toxicology results arguing the warrant lacked probable cause.
- The trial court denied suppression, admitted the toxicology report at bench trial, convicted Haselden of operating while intoxicated, and sentenced him to 30 days in Community Corrections.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether the warrant-supported blood draw lacked probable cause because observations (slurred speech, dilated pupils) can indicate non-intoxication causes | State: Officer’s observations and circumstances provided a fair probability of intoxication supporting probable cause | Haselden: Physical signs (slurred speech, dilated pupils) are consistent with medical injury/conditions and do not establish nexus to intoxication; warrant thus unsupported | Court: Magistrate had a substantial basis for probable cause; admission was not an abuse of discretion |
Key Cases Cited
- Clark v. State, 994 N.E.2d 252 (discussing standard of appellate review for evidentiary rulings)
- Combs v. State, 895 N.E.2d 1252 (search warrants require probable cause under federal and state constitutions)
- Query v. State, 745 N.E.2d 769 (reviewing magistrate’s substantial-basis probable cause determination; consider only affidavit evidence)
- Illinois v. Gates, 462 U.S. 213 (totality-of-the-circumstances standard for probable cause)
- Hannoy v. State, 789 N.E.2d 977 (minimal evidence can suffice to establish probable cause for OWI)
- Rios v. State, 762 N.E.2d 153 (boilerplate affidavit language permissible if affidavit contains sufficient case-specific facts)