State of Delaware v. Dartanya Murray
1611018155
| Del. Ct. Com. Pl. | Nov 20, 2017Background
- On Nov. 27, 2016, police responded to a three‑vehicle crash on I‑495; one vehicle (registered to Murray) was stationary, facing the wrong way, with extensive front‑end damage and visible blood in the passenger side.
- Two injured persons (Murray and passenger Edmond Triplett) were taken to Wilmington Hospital; Trooper Lawson interviewed them at the hospital and reported Murray admitted she had been drinking at a birthday party in Philadelphia and that her eyes were bloodshot and glassy.
- Trooper Galiani prepared a blood‑search‑warrant affidavit incorporating Lawson’s account (but omitted any express statement in the affidavit that an odor of alcohol was detected).
- A Justice of the Peace signed the warrant; Murray’s blood was drawn at ~3:55 a.m. and returned a BAC of 0.05. Murray was thereafter charged with DUI and other traffic offenses.
- Murray moved to suppress the blood result and hospital statements, arguing the affidavit failed the four‑corners probable‑cause test and contained recklessly omitted/false statements (Franks claim); she also raised Miranda issues (later treated as moot).
- The court ruled the affidavit did not establish probable cause within its four corners and—because Delaware does not apply the good‑faith exception in this context—suppressed the blood results; the court nonetheless found probable cause for several non‑DUI charges (e.g., leaving the scene).
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Murray) | Held |
|---|---|---|---|
| Whether the four‑corners of the affidavit established probable cause to issue a warrant for a blood draw for DUI evidence | The affidavit’s totality (accident, Murray’s admission she drank, her statement she was driving, and bloodshot/glassy eyes) sufficed for probable cause without an odor finding or field tests | Affidavit lacks temporal or corroborating indicia (no odor, no slurred speech, no evidence of when/how much she drank, no erratic driving); thus insufficient under four‑corners | Held: affidavit did not establish probable cause within its four corners; warrant invalid and blood results excluded |
| Whether omissions/false statements in the affidavit (Franks claim) require suppression | State argued no basis to void warrant on Franks grounds at this stage; omissions do not automatically trigger Franks without preliminary showing | Murray alleged reckless omissions (e.g., failure to include odor) undermined probable cause; sought Franks relief | Court found Franks analysis unnecessary because the affidavit itself failed four‑corners review; noted Franks hearing would be the proper vehicle if defendant made the required preliminary showing |
| Whether hospital statements required Miranda warnings and should be suppressed | State relied on hospital context and subsequent developments to minimize Miranda concerns; argued issue was moot | Murray argued statements at hospital were un‑Mirandized and involuntary due to injury/medication | Court treated Miranda claim as moot in light of other rulings and found hospital statements issue not determinative; also noted physical incapacity alone does not trigger Miranda protections |
Key Cases Cited
- Franks v. Delaware, 438 U.S. 154 (U.S. 1978) (defendant may obtain hearing to challenge affidavit if preliminary showing that false statements/omissions were made knowingly or recklessly)
- Skinner v. Ry. Lab. Execs.’ Ass’n, 489 U.S. 602 (U.S. 1989) (blood tests are highly intrusive searches implicating Fourth Amendment concerns)
- Dorsey v. State, 761 A.2d 807 (Del. 2000) (Delaware statutory and constitutional probable‑cause requirements and exclusionary rule under state constitution)
- Fink v. State, 817 A.2d 781 (Del. 2003) (four‑corners requirement for search‑warrant affidavits)
- Rybicki v. State, 119 A.3d 663 (Del. 2015) (magistrate may draw reasonable inferences from affidavit; totality‑of‑circumstances test for warrants)
- Bease v. State, 884 A.2d 495 (Del. 2005) (factors supporting probable cause: odor, admission of drinking, bloodshot eyes, and traffic violation)
- Miller v. State, 4 A.3d 371 (Del. 2010) (temporal admission of drinking and odor combined with field tests can support probable cause)
- Maxwell v. State, 624 A.2d 926 (Del. 1993) (post‑accident indicia—including odor and containers in vehicle—can support probable cause)
- Lambert v. State, 110 A.3d 1253 (Del. 2015) (affidavit may support inference of driver fault from collision facts)
- Lefebvre v. State, 19 A.3d 287 (Del. 2011) (combination of traffic offense, odor, flushed face, and timely admission can establish probable cause)