People v. Brooks
2017 IL 121413
| Ill. | 2018Background
- Michael Brooks was arrested after a single-vehicle motorcycle accident and taken by ambulance to St. Anthony’s Memorial Hospital; police physically forced him into the ambulance and handcuffed him for transport.
- At the hospital Officer Webb read the statutory DUI warning and requested consent for blood/breath testing; Brooks refused testing and medical staff set his broken leg.
- The State subpoenaed the hospital for Brooks’s lab results and delivered a sealed envelope to the circuit court, but the envelope was never opened or introduced at the suppression hearing.
- Brooks moved to suppress blood-alcohol results, arguing a hospital blood draw (allegedly performed) was a warrantless governmental search; the circuit court granted suppression and the appellate court affirmed.
- The Illinois Supreme Court granted leave, reviewed the suppression record (no hospital witnesses, no direct evidence a blood draw occurred, Officer Webb testified he did not request a draw), and reversed the lower courts.
Issues
| Issue | Plaintiff's Argument (People) | Defendant's Argument (Brooks) | Held |
|---|---|---|---|
| Did a blood draw occur at the hospital? | Parties proceeded as if a draw occurred; subpoena suggests lab results exist. | Brooks asserted a draw occurred and was used against him. | No evidence at hearing proved a blood draw occurred; defendant failed to meet his burden. |
| If a draw occurred, was it state action (governmental search)? | The State argued any draw was private unless hospital acted as agent of police. | Brooks argued police compelled him to the hospital and thus any draw was government action. | No evidence showed hospital staff acted at police direction; mere forcible transport does not prove agency. |
| If a draw occurred and was state action, did it violate the Fourth Amendment (warrant/exigency)? | State did not claim a warrant or an applicable exception. | Brooks relied on lack of warrant and absence of exigent circumstances. | Court did not reach exigency because defendant failed to prove state action or that a draw occurred; in any event, record supports private-search characterization. |
| Burden of proof at suppression hearing | State argued defendant failed to prove a draw. | Brooks proceeded on assumption a draw occurred and argued illegality. | Defendant bears burden to make a prima facie case; he failed to prove the search or illegality. |
Key Cases Cited
- Schmerber v. California, 384 U.S. 757 (blood tests are searches under the Fourth Amendment)
- Missouri v. McNeely, 569 U.S. 141 (warrantless blood draws require consideration of exigent circumstances)
- Coolidge v. New Hampshire, 403 U.S. 443 (test for attributing private conduct to the state: totality of circumstances/agency)
- Burdeau v. McDowell, 256 U.S. 465 (Fourth Amendment does not apply to purely private searches)
- United States v. Jacobsen, 466 U.S. 109 (private searches do not implicate Fourth Amendment even if unreasonable)
- People v. Heflin, 71 Ill. 2d 525 (private-search doctrine and state-action analysis in Illinois)