State v. Dean M. Blatterman, 864 N.W.2d 26

Blatterman was stopped following a wife's report that he might blow up the house by drawing gas in and may be intoxicated, with a history including prior OWI convictions.
Police conducted a high-risk stop, detained Blatterman, observed chest pain, and sought medical assessment for potential carbon monoxide exposure and other concerns.
Officers learned Blatterman had three prior OWI convictions, lowering the PAC threshold to 0.02% for this offender.
Blatterman was transported to St. Mary's hospital for evaluation; EMS evaluated but Blatterman declined treatment at the scene.
Hospital blood was drawn after Blatterman performed field sobriety tests; BAC measured 0.118%, exceeding the 0.02% PAC applicable to him.
Blatterman moved to suppress the blood-test results as unlawful arrests; the circuit court denied, the court of appeals reversed, and the supreme court granted review.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the stop and detention were constitutionally reasonable	Blatterman—argues the stop was overbroad; lack of probable cause to arrest at the scene.	State—detention was based on reasonable suspicion and within Terry/§ 968.24 guidance; medical concerns justified extension.	Temporary detention supported by reasonable suspicion was reasonable.
Whether transporting to the hospital within the vicinity of the stop kept the detention lawful	Transport outside the vicinity turned the stop into an arrest without probable cause.	-k	Ten-mile transport exceeded the vicinity; thus not within the initial Terry detention.
Whether there was probable cause to arrest for PAC at the time of transport	Arrest/ testing should rely on circumstances at the time of transport with probable cause tied to PAC.	With knowledge of three prior OWI convictions, odor of intoxicants, and PAC threshold of 0.02%, probable cause existed to arrest for PAC.	There was probable cause to arrest for a 0.02% PAC offense at the time of transport.
Whether the community caretaker exception justified the transport	Transport to hospital could be justified as a community caretaker function in the absence of probable cause.	The officer acted as both caretaker and enforcer; transportation was reasonable to protect Blatterman and others.	Transportation to the hospital satisfied the community caretaker exception as a bona fide function.

State v. Lange, 317 Wis. 2d 383 (Wis. 2009) (probable cause standard for PAC under .02% limit; arrest analysis)
State v. Pinkard, 327 Wis.2d 346 (Wis. 2010) (community caretaker and detention reasonableness framework)
State v. Vorburger, 255 Wis.2d 537 (Wis. 2002) (objective test for whether seizure escalates to arrest)
State v. Goss, 338 Wis.2d 72 (Wis. 2011) (odor can establish probable cause to request PBT for .02% PAC offenders)
State v. Colstad, 260 Wis.2d 406 (Wis. 2003) (medical assistance can justify extended detention in an accident scene)
Kramer v. State, 315 Wis.2d 414 (Wis. 2008) (three-component test for community caretaker function)
State v. Arias, 311 Wis.2d 358 (Wis. 2008) (standard for evaluating temporary detentions and certainty of suspect status)
State v. Secrist, 224 Wis.2d 201 (Wis. 1999) (probable cause and its application in warrant-less arrests)
Cady v. Dombrowski, 413 U.S. 433 (U.S. 1973) (community caretaking function_origin in vehicle contexts)
Missouri v. McNeely, 569 U.S. _ (U.S. 2013) (blood draws in drunk-driving cases may require exigent circumstances or warrants)