State v. Doyle, 55 A.3d 805

Defendant Doyle was involved in a severe automobile accident injuring a bystander, Schaus, who required Life Star transport to a hospital.
Troopers detected the odor of alcohol on Doyle and administered three field sobriety tests, after which they determined no probable cause to arrest yet.
Doyle was not restrained or arrested at the scene and was free to move and converse with his father; police discussed taking a blood sample with Doyle.
Doyle signed a consent form for a blood test at the accident scene and then again at the hospital, with no questions asked about consent.
Blood drawn at the hospital tested elevated for alcohol; Doyle was charged with DUI under § 14-227a (a)(2) and other counts, with suppression motions denied.
Doyle appealed, challenging both the voluntariness of consent and any alleged unconstitutional seizure at the scene.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was Doyle's blood test consent free and voluntary?	State: consent was voluntary under totality of circumstances.	Doyle: consent not voluntary due to surrounding circumstances and coercion risks.	Consent found voluntary; not clearly erroneous.
Did an unconstitutional seizure precede the blood test?	State: no seizure; detention was consensual or justified by reasonable suspicion.	Doyle: continued detention after field tests violated the Fourth Amendment/Article I, § 7.	Detention reasonable under totality of circumstances; no illegal seizure.

State v. Jenkins, 298 Conn. 209 (2010) (burden to prove voluntary consent by preponderance of the evidence)
State v. Boyd, 296 Conn. 707 (2010) (standard for appellate review of trial court factual findings in suppression rulings)
State v. Brunetti, 279 Conn. 39 (2006) (consent to searches under Fourth Amendment framework)
State v. Greenfield, 228 Conn. 62 (1993) (absence of express warning about right to leave; totality of circumstances analysis)
United States v. Mendenhall, 446 U.S. 544 (1980) (factors indicating seizure; consent admissibility considerations)
Ohio v. Robinette, 519 U.S. 33 (1996) (police not required to inform detainee they are free to leave for consent to search)
State v. Cortez, 449 U.S. 411 (1981) (totality of circumstances in assessing reasonable suspicion)
State v. Clark, 297 Conn. 1 (2010) (stop/detention standard for reasonable and articulable suspicion)
State v. Stevens, 26 Conn. App. 805 (1992) (swift apprehension of intoxicated drivers and testing considerations)
State v. Doyle, 104 Conn. App. 4 (2007) (noncoercive presence of police at accident scene; physical restraint considerations)
United States v. Watson, 423 U.S. 411 (1976) (consent given on public street; lack of coercion or threats)
United States v. Kimball, 25 F.3d 1 (1st Cir. 1994) (consent to accompany officers without explicit free-to-leave right)