224 A.3d 1035
Me.2020Background
- Multi-vehicle, chaotic Route 17 crash (five vehicles, one engulfed in flames); two drivers appeared dead and Randall Weddle was pinned and later extricated and airlifted to a hospital.
- A Knox County sergeant, believing Weddle might be responsible but without probable cause that he was intoxicated, directed an EMT to obtain a blood sample at the scene under Maine’s mandatory post‑fatal‑crash blood‑test statute, 29‑A M.R.S. § 2522(2).
- No warrant was sought and no consent was obtained before the scene blood draw; a later hospital blood sample (with Weddle’s consent) showed BAC 0.07.
- Weddle was indicted for manslaughter, causing death while OUI, and related offenses; he moved to suppress the scene blood result, which the trial court denied; jury convicted and sentenced.
- The Maine Supreme Judicial Court held § 2522(2)–(3) unconstitutional on its face (overruling State v. Cormier), but affirmed the denial of suppression because the officer reasonably relied in good faith on the statute and prior precedent, so the exclusionary rule did not bar admission.
Issues
| Issue | Weddle's Argument | State's Argument | Held |
|---|---|---|---|
| 1) Is 29‑A M.R.S. § 2522 constitutional on its face (mandatory warrantless blood draws after fatal/likely‑fatal crashes)? | § 2522 authorizes intrusive, nonconsensual blood draws without probable cause and is therefore facially unconstitutional under the Fourth Amendment. | § 2522 addresses exigent public‑safety circumstances and includes safeguards (admissibility conditioned on independent probable cause), so it is constitutional, at least as applied to fatal crashes. | Court: § 2522(2)–(3) is facially unconstitutional because it permits blood draws without prior probable cause and is tied to law enforcement purposes; Cormier overruled. |
| 2) Can probable cause be established after a blood draw to justify the search? | No — evidence obtained after the search cannot retroactively supply probable cause for the earlier intrusion. | The statute contemplates post‑draw evidence that can establish independent probable cause for admissibility. | Court: Post‑hoc establishment of probable cause cannot validate the initial warrantless intrusion; evidence gathered after the draw cannot justify the prior search. |
| 3) Does the special‑needs doctrine permit warrantless mandatory blood draws under § 2522? | No — § 2522’s primary purpose is law enforcement/evidentiary, so special needs do not apply. | The state argued public‑safety and regulatory interests justify a special‑needs exception in these narrow, exigent circumstances. | Court: Special‑needs exception inapplicable because the statute is primarily law‑enforcement‑oriented (Ferguson, Skinner distinctions). |
| 4) If the draw violated the Fourth Amendment, is suppression required or does a good‑faith exception apply? | Suppression required under exclusionary rule. | Officer acted in objectively reasonable, good‑faith reliance on statute and controlling precedent (Cormier, Roche), so exclusionary rule should not apply. | Court: Good‑faith exception applies in these unique circumstances; suppression would not further deterrence, so admission affirmed. |
Key Cases Cited
- State v. Cormier, 928 A.2d 753 (Me. 2007) (previously upheld mandatory post‑fatal‑crash blood draw statute; overruled here).
- Missouri v. McNeely, 569 U.S. 141 (2013) (emphasized blood draws implicate significant privacy interests and exigency is fact‑specific).
- Birchfield v. North Dakota, 136 S. Ct. 2160 (2016) (distinguished breath and blood testing; protections for blood draws).
- Ferguson v. City of Charleston, 532 U.S. 67 (2001) (special‑needs doctrine inapplicable where primary purpose is law enforcement evidence).
- Skinner v. Ry. Labor Execs.’ Ass’n, 489 U.S. 602 (1989) (special‑needs justification for testing safety‑sensitive employees).
- United States v. Leon, 468 U.S. 897 (1984) (articulated good‑faith exception to exclusionary rule for reasonable reliance on a warrant).
- Illinois v. Krull, 480 U.S. 340 (1987) (good‑faith reliance on statute can justify admission absent clear unconstitutionality).
- Schmerber v. California, 384 U.S. 757 (1966) (upheld blood draw at hospital after accident under exigent‑circumstances analysis).