State of Arizona v. Francisco L Encinas Valenzuela
239 Ariz. 299
| Ariz. | 2016Background
- DPS officer arrested Francisco Valenzuela for DUI after finding him asleep in his truck with engine running and signs of intoxication.
- At the station the officer read an “admin per se” form stating (repeatedly) that “Arizona law requires you to submit” to breath, blood, or other tests and warned of license suspension for refusal.
- Valenzuela said he understood and submitted to breath and blood tests; results produced AC > 0.20 and he was charged with aggravated DUI counts.
- Valenzuela moved to suppress the test results arguing his consent was involuntary because it followed the officer’s admonition; the trial court denied suppression and convictions followed.
- The court of appeals affirmed (divided); this Court granted review to resolve whether consent given after the implied-consent admonition is voluntary for Fourth Amendment purposes.
- The Supreme Court held consent was involuntary under the Fourth Amendment but applied the good-faith exception to affirm the denial of suppression and the convictions.
Issues
| Issue | Valenzuela's Argument | State's Argument | Held |
|---|---|---|---|
| Whether consent to blood/breath testing was voluntary when given after officer told him Arizona law "requires" submission | The admonition coerced him; his assent was mere acquiescence to claimed authority | Totality of circumstances show voluntary consent; Bumper is distinguishable | Consent was involuntary; repeated admonition invoked lawful authority and tainted consent |
| Whether Arizona's implied-consent statute itself provides constitutionally valid consent to a warrantless search | Implied-consent cannot substitute for voluntary Fourth Amendment consent | Operating a vehicle gives statutory consent; statute’s penalties enforce compliance | Statute does not supply Fourth Amendment consent; independent voluntary consent is required |
| Whether the exclusionary rule bars admission of test results despite involuntary consent (good-faith exception) | Evidence should be excluded because admonition coerced consent and law enforcement reliance was unreasonable | Officer relied on existing precedent and common admin per se form; good-faith exception applies | Good-faith exception applies because the officer relied on binding precedent and acted objectively reasonably; suppression not required |
Key Cases Cited
- Schneckloth v. Bustamonte, 412 U.S. 218 (consent to search governed by totality-of-circumstances; prosecution must prove voluntariness)
- Bumper v. North Carolina, 391 U.S. 543 (consent is invalid if it is mere acquiescence to claimed lawful authority)
- Missouri v. McNeely, 569 U.S. 141 (blood draws are searches; exigency analysis requires case-by-case review)
- Carrillo v. Houser, 224 Ariz. 463 (officer generally needs express consent or warrant before administering tests under Arizona implied-consent statute)
- Butler v. State, 232 Ariz. 84 (DUI blood/breath tests are searches subject to Fourth Amendment)
- Davis v. United States, 564 U.S. 229 (good-faith exception: exclusion unnecessary when officers act with objectively reasonable belief in legality)
- Herring v. United States, 555 U.S. 135 (exclusionary rule requires sufficiently deliberate or culpable police conduct to deter)
- Lo-Ji Sales, Inc. v. New York, 442 U.S. 319 (consent given after colorably lawful coercion is invalid)
