State of Tennessee v. Corrin Kathleen Reynolds
504 S.W.3d 283
| Tenn. | 2016Background
- Single-vehicle crash (Oct. 29, 2011) killed two occupants; Corrin K. Reynolds was injured and taken to UT Medical Center where a deputy interviewed survivors and directed a hospital phlebotomist to draw Reynolds’s blood without obtaining a warrant.
- Deputy Strzelecki testified Reynolds said “Do whatever you have to do,” smelled of alcohol, admitted (verbally or nonverbally) she was the driver and that others drank, and performed poorly on an HGN test; medical records show she received sedatives and pain medication and later denied recollection.
- Trial court initially denied suppression (found verbal consent), then after additional medical and expert testimony granted suppression (found no actual consent and insufficient probable cause for implied-consent mandatory draw).
- Court of Criminal Appeals reversed: it agreed lack of actual consent but held probable cause existed (fatal accident, odor, admission, HGN) triggering Tennessee’s implied-consent statute; alternatively endorsed good-faith exception.
- Tennessee Supreme Court held the warrantless blood draw violated the Fourth Amendment and Tennessee Constitution but adopted the Davis good-faith exception and affirmed admission of the blood-test evidence because the officer reasonably relied on pre-McNeely precedent that treated alcohol dissipation as a per se exigency.
Issues
| Issue | State's Argument | Reynolds's Argument | Held |
|---|---|---|---|
| Probable cause to believe driver was DUI (to trigger implied-consent) | Facts (fatal crash, odor of alcohol, admission, HGN performance) furnished probable cause | Officer lacked probable cause; HGN and admissions unreliable due to injuries/meds | Probable cause existed under the totality of circumstances (officer’s knowledge at time controlling) |
| Whether Tennessee implied-consent statute supplies consent exception to warrant requirement | Statutory implied consent justifies warrantless draw if probable cause and no withdrawal | Implied consent inapplicable here; capacity to revoke and voluntariness lacking given injuries/meds | Court declined to decide broadly; with facts here defendant likely could not revoke implied consent, so statute not resolved in this opinion |
| Whether the warrantless blood draw violated Fourth Amendment / Tenn. Const. art. I §7 | N/A (State conceded lack of actual consent on appeal) | Warrantless blood draw was unconstitutional (no exigency, no valid consent) | Court: the draw did violate federal and state constitutional protections |
| Applicability of exclusionary rule — adoption and application of Davis good-faith exception | Exclude suppression because officer reasonably relied on binding state precedent treating dissipation as exigency; adopt Davis exception | Exclude the good-faith exception; violations should lead to suppression to vindicate constitutional rights | Court adopted the Davis good-faith exception (narrowly) and held it applies here because officers relied on binding precedent pre-McNeely; evidence need not be suppressed |
Key Cases Cited
- Davis v. United States, 564 U.S. 229 (2011) (good-faith exception applies where police reasonably rely on binding appellate precedent)
- Missouri v. McNeely, 569 U.S. 141 (2013) (natural dissipation of alcohol is not a per se exigency; exigency must be assessed case-by-case)
- Birchfield v. North Dakota, 136 S. Ct. 2160 (2016) (breath tests permissible as search incident to arrest; blood tests are not; discussion of implied-consent limits)
- Schmerber v. California, 384 U.S. 757 (1966) (upheld warrantless blood draw under exigent circumstances given facts)
- United States v. Leon, 468 U.S. 897 (1984) (established good-faith exception for warrant reliance)
- Weeks v. United States, 232 U.S. 383 (1914) (origin of exclusionary rule for federal courts)
- Mapp v. Ohio, 367 U.S. 643 (1961) (applied exclusionary rule to states)