State of Tennessee v. Scarlet I. Martin
M2016-00615-CCA-R3-CD
| Tenn. Crim. App. | May 11, 2017Background
- Scarlet I. Martin was indicted for DUI and DUI per se after a single-vehicle crash on Feb. 5–6, 2014; bench trial conviction followed denial of a suppression motion.
- Trooper Campbell investigated the crash, waited at scene for about an hour (to secure vehicle/tow), then went to the hospital where he smelled alcohol on Martin, observed slurred speech, and obtained admissions she had been drinking.
- Martin refused to consent to a blood draw; Trooper Campbell ordered a warrantless involuntary blood draw about two hours and 25–30 minutes after the crash; TBI testing showed BAC .17.
- Trooper Campbell testified he could have sought a warrant but believed obtaining one that night would take roughly an hour and risked the dissipation of alcohol evidence or release of the suspect.
- Trial court credited Trooper Campbell, denied suppression, and convicted Martin; the Court of Criminal Appeals affirmed, holding the warrantless draw was justified by exigent circumstances.
Issues
| Issue | Plaintiff's Argument (State) | Defendant's Argument (Martin) | Held |
|---|---|---|---|
| Sufficiency of evidence for DUI/DUI-per-se | Evidence (odor, slurred speech, admission, BAC .17) proves impairment and BAC > .08 | Evidence insufficient / facts do not establish elements | Held: Evidence sufficient; convictions affirmed |
| Validity of warrantless blood draw (Fourth Amendment) | Warrantless draw justified by exigent circumstances: delay to obtain warrant would significantly undermine evidence collection | Exigency was not shown and, if any, was created by law enforcement failure to obtain a warrant | Held: Warrantless draw justified—totality showed exigency (time elapsed, single trooper, tow/medical delay); not created by state actors |
Key Cases Cited
- State v. Evans, 838 S.W.2d 185 (Tenn. 1992) (standard for appellate review of sufficiency)
- Jackson v. Virginia, 443 U.S. 307 (1979) (Jackson standard: whether any rational trier of fact could find guilt beyond a reasonable doubt)
- Missouri v. McNeely, 133 S. Ct. 1552 (2013) (warrantless blood draws require case-by-case exigency analysis because alcohol dissipates)
- Birchfield v. North Dakota, 136 S. Ct. 2160 (2016) (constitutional protection for blood draws in DUI context)
- Schmerber v. California, 384 U.S. 757 (1966) (recognizes exigent-circumstances exception for involuntary blood draws)
- State v. Meeks, 262 S.W.3d 710 (Tenn. 2008) (Tennessee application of warrant/exigency principles in DUI blood-draw context)