State Of Washington v. Anthony Youngs, 199 Wash. App. 472

Early morning May 15, 2013: Trooper arrested Anthony Youngs after a single-car rollover and transported him to a hospital; trooper sought a warrant to draw Youngs’s blood.
Affidavit for the blood-draw warrant used a largely preprinted form with typed insertions by the trooper; affidavit alleged intoxication signs (odor, admission of ~4 beers, bloodshot/slurred speech, nystagmus, .114 PBT) but did not expressly state Youngs was driving.
The affidavit included preprinted language stating the warrant was requested “2 hours 15 minutes after Anthony Youngs ceased driving/was found in physical control of a motor vehicle,” but the warrant form identified the offense as Driving While Under the Influence (RCW 46.61.502), and boxes for Physical Control (RCW 46.61.504) were left unchecked.
Youngs moved to suppress evidence obtained under the warrant; the district court denied suppression, Youngs stipulated to a bench trial and was convicted; the RALJ and superior court affirmed the warrant issuance.
The Court of Appeals granted discretionary review to decide whether the magistrate had sufficient independent facts in the affidavit to find probable cause that Youngs was driving.

Issue	Plaintiff's Argument (State)	Defendant's Argument (Youngs)	Held
Whether the affidavit supplied sufficient facts for a neutral magistrate to independently find probable cause that Youngs was driving the vehicle involved in the rollover so as to justify a warrant for a blood draw	Read commonsensely, the affidavit’s combination of the ‘‘involved in a one car rollover’’ statement, preprinted ‘‘was found in physical control’’ language, and intoxication indicators supplied probable cause	The affidavit is conclusory and lacks specific factual statements tying Youngs to the act of driving (e.g., observed driving, proximity to keys), so it cannot support a magistrate’s independent probable-cause determination	The affidavit was insufficient; the warrant lacked adequate factual basis to show probable cause that Youngs was driving, so evidence obtained must be suppressed

State v. Clark, 143 Wn.2d 731 (discusses probable cause requirement for warrants)
State v. Lyons, 174 Wn.2d 354 (affidavit must provide substantial basis for magistrate; ambiguous timing can vitiate probable cause)
In re Yim, 139 Wn.2d 581 (negligent omissions in affidavit may be excused when other detailed facts permit magistrate inference)
State v. Stephens, 37 Wn. App. 76 (one-word or conclusory summaries in affidavit insufficient without underlying facts)
State v. Thein, 138 Wn.2d 133 (generalized, experience-based assertions about typical criminal behavior insufficient to establish nexus to residence)
State v. Neth, 165 Wn.2d 177 (standard of review and magistrate’s neutral/detached role in warrant issuance)