Lambert v. State
110 A.3d 1253
| Del. | 2015Background
- In Nov. 2013 Lambert's motorcycle rear-ended an SUV; he was semi‑conscious on a backboard with blood around his nose and mouth.
- Corporal Lowman smelled a moderate odor of alcohol on Lambert’s breath and observed bloodshot, watery eyes.
- Lambert admitted he hit the Trailblazer but, due to injuries, could not perform field sobriety tests; a blood sample was drawn showing BAC .19.
- Lambert was charged with felony DUI (fourth offense) and other traffic offenses; he later admitted guilt at trial by stipulation after the suppression ruling.
- Lambert moved to suppress the blood test on the ground the search‑warrant affidavit lacked probable cause; the Superior Court denied the motion.
- On appeal, the Delaware Supreme Court reviewed whether the four‑corners of the affidavit provided probable cause to believe Lambert operated his vehicle while under the influence.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Lambert) | Held |
|---|---|---|---|
| Whether the affidavit established probable cause to issue a warrant for blood draw | Affidavit facts (rear‑end collision, victim identified as driver, odor of alcohol, bloodshot/watery eyes, admission of hitting vehicle) collectively support a fair probability Lambert drove under the influence | Affidavit failed to show impairment or fault; omitted signs like confusion/disorientation and did not affirmatively establish causation of the crash | Affirmed: totality of circumstances (collision + odor + bloodshot eyes + admission) supplied probable cause for warrant |
Key Cases Cited
- Rivera v. State, 7 A.3d 961 (Del. 2010) (probable‑cause affidavit standard and totality‑of‑circumstances analysis)
- Morgan v. State, 962 A.2d 248 (Del. 2008) (discussion of affidavit sufficiency supporting warrants)
- Sisson v. State, 903 A.2d 288 (Del. 2006) (totality‑of‑the‑circumstances test for probable cause)
- Maxwell v. State, 624 A.2d 926 (Del. 1993) (probable cause does not require proof beyond a reasonable doubt; innocent explanations do not preclude probable cause)
- Jarvis v. State, 600 A.2d 38 (Del. 1991) (probable cause may exist despite facts susceptible to innocent explanations)
- Bease v. State, 884 A.2d 495 (Del. 2005) (supporting precedent for probable‑cause findings in DUI contexts)