State of Arizona v. Courtney Noelle Weakland, 246 Ariz. 67

Background

In Feb 2015 Oro Valley police arrested Courtney Weakland for DUI, read her an "admin per se" form stating Arizona law "requires" submission to blood testing, and obtained a warrantless blood draw showing BAC .218.
Weakland moved to suppress the blood evidence as involuntary consent induced by the admonition; the trial court denied the motion and she was convicted.
On appeal the State conceded the consent was invalid under State v. Valenzuela (Valenzuela II) but argued the good-faith exception to the exclusionary rule saved the evidence; the court of appeals affirmed.
The Arizona Supreme Court granted review to decide whether the good-faith exception applies to blood draws taken after State v. Butler (2013) but before Valenzuela II (2016).
The central factual/legal question: whether officers reasonably relied on binding precedent authorizing the admin per se admonition (so exclusionary rule deterrence does not apply).

Issues

Issue	Plaintiff's Argument (Weakland)	Defendant's Argument (State)	Held
Whether the good-faith exception to the exclusionary rule applies to admit blood evidence obtained after Butler but before Valenzuela II	Butler unsettled the law; reading the admonition that a suspect is "required" to submit made any consent involuntary, so exclusion should apply	Police reasonably relied on longstanding appellate authority authorizing the admonition (Campbell, Brito) and therefore acted in objectively reasonable good faith	Good-faith exception applies; convictions affirmed
Whether Butler "unsettled" the law as to use of the admin per se admonition	Butler placed police on notice that relying on the admonition alone was constitutionally suspect	Butler did not repudiated prior appellate authority; subsequent appellate decisions continued to approve the admonition, so law was not unsettled	Butler did not sufficiently unsettle the law; officers could reasonably rely on existing appellate precedent
Proper standard for good-faith exception (specific authorization vs. reasonableness)	Good-faith requires binding appellate precedent that specifically authorizes the precise practice	Good-faith applies where officers acted in objectively reasonable reliance on binding appellate precedent or its rationale	Court adopts Jean's reasonableness approach (not limited to literal specific authorization)
Whether deterrence supports exclusion here	Exclusion needed because police should have erred on side of constitutional behavior after Butler	Exclusion would not deter deliberate police misconduct because officers followed existing appellate practice; exclusion is last resort with heavy costs	Deterrence rationale fails; exclusion unwarranted here

Key Cases Cited

State v. Butler, 232 Ariz. 84 (Ariz. 2013) (held Fourth Amendment requires voluntariness inquiry independent of implied-consent statute)
State v. Valenzuela, 239 Ariz. 299 (Ariz. 2016) (Valenzuela II) (held consent given only in response to admin per se admonition cannot prove voluntariness; applied good-faith exception to earlier arrest)
State v. Havatone, 241 Ariz. 506 (Ariz. 2017) (declined good-faith exception where practice had been discredited and no binding precedent specifically authorized it)
State v. Jean, 243 Ariz. 331 (Ariz. 2018) (applied a reasonableness-based good-faith standard extending precedent rationale to new practices)
Davis v. United States, 564 U.S. 229 (2011) (federal good-faith precedent; exclusionary rule inapplicable when officers reasonably rely on binding appellate precedent)
United States v. Leon, 468 U.S. 897 (1984) (established good-faith exception to exclusionary rule)
Bumper v. North Carolina, 391 U.S. 543 (1968) (consent induced by assertion of lawful authority is not voluntary)
Schneckloth v. Bustamonte, 412 U.S. 218 (1973) (voluntariness of consent assessed under totality of circumstances)
Campbell v. Superior Court, 106 Ariz. 542 (Ariz. 1971) (early appellate decision treated implied-consent statute permissively)
State v. Brito, 183 Ariz. 535 (Ariz. Ct. App. 1995) (court of appeals treated admonition language as lawful in relevant contexts)