Sanchez v. State, 365 S.W.3d 681

Sanchez involved in a single-vehicle Harris County crash shortly after midnight on March 22, 2009.
The passenger said Sanchez lost control, drove over a curb, and hit a retaining wall; Sanchez admitted consuming a couple of beers.
During field sobriety tests, Sanchez showed clues of intoxication and was arrested; he refused a breath sample.
An officer sought a blood-draw search warrant; the warrant was signed by a Montgomery County statutory county court judge.
The warrant commanded a peace officer in Harris County to seize Sanchez and draw his blood; BAC was 0.163.
On appeal, Sanchez argued the Montgomery County judge lacked authority to issue a warrant for blood drawn in Harris County; the trial court denied suppression; Sanchez pled guilty and was sentenced.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether a statutory county court judge can issue a blood warrant for execution outside his county	State: no geographical limit to jurisdiction; statewide issuance implied	Sanchez: lacks statewide authority; jurisdiction limited to own county	Statutory county court judges lack authority to issue warrants outside their county

Schmerber v. California, 384 U.S. 757 (U.S. Supreme Court 1966) (blood draw as a search under Fourth Amendment)
Powell v. State, 898 S.W.2d 821 (Tex. Crim. App. 1994) (arrest/search warrant distinctions in context)
Hinkley v. State, 45 S.W.2d 581 (Tex. Crim. App. 1931) (arrest vs. blood-draw warrant treatment)
Beeman v. State, 86 S.W.3d 613 (Tex. Crim. App. 2002) (Fourth Amendment and blood-draw warrants)
Conine, 33 F.3d 467 (5th Cir. 1994) (magistrate authority and state-wide reach)
Steagald v. United States, 451 U.S. 204 (U.S. Supreme Court 1981) (scope of warrants and residence of subject)