State of Tennessee v. Dennis Sprawling
W2014-02511-CCA-R9-CD
| Tenn. Crim. App. | Jul 5, 2016Background
- Late-night traffic stop: Lieutenant Kant observed the driver (Dennis Sprawling) weaving and stopped him; officer smelled alcohol and placed Sprawling under arrest for DUI.
- Prior conviction known: DUI Unit Officer Ken Fox learned Sprawling had a prior DUI conviction before testing.
- Implied-consent interaction: Officer Fox advised Sprawling of Tennessee’s implied consent law (as understood in April 2013) and told him that, because of the prior conviction, he "must" give blood; Sprawling responded "okay."
- Blood drawn without warrant: A nurse drew two tubes of blood at the precinct and samples were sent to the TBI; no search warrant was obtained.
- Trial court suppression: The trial court found Sprawling’s acquiescence was coerced (not voluntary consent) and suppressed the blood-test results, concluding the mandatory-draw statute did not eliminate the Fourth Amendment warrant requirement.
- Interlocutory appeal: The State appealed the suppression order arguing actual and statutory (implied) consent; the Court of Criminal Appeals affirmed the suppression.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether officer had actual consent for a warrantless blood draw | State: totality shows Sprawling voluntarily consented (he said "okay") | Sprawling: his "okay" reflected resignation/coercion, not voluntary consent | Held: No actual consent; trial court’s factual finding that consent was coerced is upheld |
| Whether implied consent statute (T.C.A. § 55-10-406) authorized a warrantless mandatory blood draw | State: driving/previous DUI created implied consent that authorized the blood draw without a warrant | Sprawling: implied-consent statute does not eliminate Fourth Amendment warrant requirement | Held: Statute does not obviate the warrant requirement; implied consent alone insufficient for forcible blood draw |
| Whether exclusionary rule/good-faith exception should save the evidence | State: good-faith reliance on statutory scheme supports admission | Sprawling: exclusion applies; Court should not adopt a state-level good-faith exception | Held: Court refused to adopt a good-faith exception under Tennessee law and affirmed suppression |
Key Cases Cited
- Coolidge v. New Hampshire, 403 U.S. 443 (per curiam) (warrantless searches outside judicial process presumptively unreasonable)
- Katz v. United States, 389 U.S. 347 (Fourth Amendment protections for searches and seizures)
- Schmerber v. California, 384 U.S. 757 (forcible blood draws are searches under the Fourth Amendment)
- Missouri v. McNeely, 133 S. Ct. 1552 (2013) (natural metabolization of alcohol does not create per se exigency for blood draw)
- State v. Ingram, 331 S.W.3d 746 (Tenn. 2011) (actual consent must be unequivocal, specific, intelligently given, and free of coercion)
- State v. Northern, 262 S.W.3d 741 (Tenn. 2008) (appellate deference to trial court factual findings on suppression)
- State v. Bartram, 925 S.W.2d 227 (Tenn. 1996) (consent is a recognized exception to the warrant requirement)