Sauls v. State, 293 Ga. 165

Sauls was stopped for erratic driving and arrested for DUI, open container, and suspended license.
Officer read the implied consent notice from a card but interrupted Sauls and omitted the sentence about evidence of refusal being admissible at trial.
Sauls refused the State-administered chemical tests.
The trial court granted suppression, finding the omission materially altered the notice.
Court of Appeals reversed suppression, finding no controlling precedent and no due process violation.
This Court held that the omission can render the notice substantively inaccurate, requiring suppression, and reversed the Court of Appeals.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Did omission of a trial-use sentence violate due process or accuracy?	Sauls (state) argued omission misled about consequences.	State argued due process not violated because testing refusal is not a constitutional right.	Omission renders notice substantively inaccurate; suppression required.

South Dakota v. Neville, 459 U.S. 553 (Supreme Court, 1983) (upholding admissibility of refusal evidence when rights are not constitutionally protected)
Chancellor v. Dozier, 283 Ga. 259 (Ga. 2008) (due process not violated when driver not told full consequences; focus on license consequences)
Klink v. State, 272 Ga. 605 (Ga. 2000) (refusal to submit testing is created by statute, not constitutional right)
State v. Barnard, 321 Ga. App. 20 (Ga. App. 2013) (substantive accuracy of implied consent notice governs suppression validity)
McHugh v. State, 285 Ga. App. 131 (Ga. App. 2007) (omissions considered potentially misleading; necessity of accuracy)
State v. Hassett, 216 Ga. App. 114 (Ga. App. 1995) (material omission may be as misleading as erroneous statement)
State v. Causey, 215 Ga. App. 85 (Ga. App. 1994) (omissions can render notice insufficiently accurate)