State v. Adams, 503 P.3d 1130

Defendant Brian Adams was arrested for DWI and taken to San Juan Regional Medical Center for a blood draw; emergency department technician (and licensed EMT) Danica Atwood drew two vials using an SLD-approved kit.
Atwood had EMT certification, hospital employment, supervised orientation, and substantial on-the-job experience performing blood draws but had no laboratory employment or formal laboratory credentials.
Magistrate denied suppression; Defendant reserved appeal when pleading no contest. The district court granted suppression, relying on Garcia (holding EMT license alone insufficient).
The Court of Appeals reversed, holding Atwood qualified as a “laboratory technician” based on her training and experience despite her title.
The New Mexico Supreme Court granted certiorari to resolve whether EMTs/emergency department technicians with blood‑draw training and experience qualify as “laboratory technician[s]” under NMSA 1978 § 66-8-103 and whether the district court abused its discretion.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether an EMT/emergency department technician with blood‑draw training and experience may qualify as a “laboratory technician” under § 66-8-103	State: term is ambiguous; “technician” focuses on acquired technique — Atwood’s training/experience satisfy the statute	Adams: “laboratory technician” should require laboratory credentials/experience; allowing EMTs renders “laboratory” surplus and undermines legislative choices	Held: Yes — when employed by a hospital or physician and possessing specific training and on‑the‑job experience performing legal blood draws, such personnel qualify as “laboratory technician[s].”
Whether the district court abused its discretion by suppressing the blood-test results	State: district court misapplied law by following a narrow reading of Garcia; evidence showed Atwood met the statutory standard	Adams: Garcia supports exclusion where EMTs lack required training; district court properly suppressed	Held: District court abused its discretion; suppression was wrongful and Court of Appeals correctly reversed and remanded for proceedings consistent with this interpretation.

State v. Garcia, 370 P.3d 791 (N.M. Ct. App. 2016) (EMT without appropriate SLD protocol training held not qualified; suppression affirmed)
State v. Adams, 447 P.3d 1142 (N.M. Ct. App. 2019) (Court of Appeals: EMT with training/experience may be a “laboratory technician”)
State v. Trujillo, 510 P.2d 1079 (N.M. Ct. App. 1973) (statute ambiguous as to licensing requirement for technologist; interpret by legislative purpose)
Steere Tank Lines, Inc. v. Rogers, 581 P.2d 456 (N.M. 1978) (describes § 66-8-103 purposes: safety of subject and reliability of sample)
State v. Wiberg, 107 N.M. 152, 154 P.2d 529 (N.M. Ct. App. 1988) (employment-by-hospital/physician requirement applies to "technologists," not all listed professions)