People v. Meza
232 Cal. Rptr. 3d 894
| Cal. Ct. App. 5th | 2018Background
- On Sept. 1, 2013 Meza crashed his car, was injured, and taken by ambulance to a hospital; officers at the scene suspected intoxication based on smell of alcohol and blood-shot eyes.
- Officer Cruz followed Meza to the hospital, told him he was under arrest for DUI and that a phlebotomist was coming; Meza said "Okay" and did not resist.
- Hospital staff drew blood at 7:08 p.m. for medical purposes (result reported as 0.148% in plasma); a police-requested forensic blood draw occurred at 8:25 p.m. (result 0.11% whole blood).
- Officer Cruz did not seek a warrant before the 8:25 p.m. forensic draw, though she knew of McNeely and had training on obtaining on-call judicial warrants.
- Trial court denied suppression, finding exigent circumstances (relying on Schmerber); the jury convicted Meza of DUI causing injury and BAC ≥ 0.08 causing injury.
- The appellate court held the warrantless police-initiated forensic blood draw violated the Fourth Amendment under the McNeely totality-of-the-circumstances test, but deemed the error harmless beyond a reasonable doubt because the hospital blood result independently established intoxication.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether exigent circumstances justified a warrantless police-initiated forensic blood draw at the hospital | Police: Schmerber and emergency/medical context justified bypassing warrant; delay would risk loss of alcohol evidence | Meza: McNeely requires totality inquiry; officers could and should have obtained an on-call warrant or sought help | The court held exigent circumstances did not justify the warrantless forensic draw under McNeely; warrant required on these facts |
| Whether Meza's acquiescence amounted to valid consent to the forensic draw | Police: Meza said "Okay," suggesting consent | Meza: Acquiescence to officer's assertion of authority does not equal valid consent | Trial court rejected consent theory at suppression hearing; appellate opinion did not rely on consent and treated draw as nonconsensual |
| Whether suppression error was harmless | People: Even if the 8:25 result excluded, hospital 7:08 result reliably showed BAC well above 0.08 | Meza: Hospital draw was medical (not forensic) and not Title 17–compliant, so it is less reliable | Held harmless beyond a reasonable doubt: hospital blood (converted to whole-blood equivalent) independently established BAC above legal limit |
| Whether any other warrant exceptions or doctrines validated the search (e.g., search-incident-to-arrest) | People: urged exigency/other justifications | Meza: Fourth Amendment protections apply; other exceptions inapplicable | Court declined to reach or accept other exceptions; focused on exigency and harmlessness |
Key Cases Cited
- Schmerber v. California, 384 U.S. 757 (reasoning approving a warrantless blood draw in that case's emergency facts)
- Missouri v. McNeely, 569 U.S. 141 (holding no per se exigency; exigency assessed by totality of circumstances and acknowledging modern warrant procedures)
- Birchfield v. North Dakota, 136 S. Ct. 2160 (recognizing blood draws are searches under the Fourth Amendment and limiting search-incident-to-arrest for blood tests)
- Mincey v. Arizona, 437 U.S. 385 (discussing exigent-circumstances exception to warrant requirement)
- Chapman v. California, 386 U.S. 18 (standard for harmless error beyond a reasonable doubt)