State v. Edwards
853 N.W.2d 246
S.D.2014Background
- On March 25, 2013 Officer Nathaniel Borg arrested Lloyd Edwards for DUI and drawing a warrantless blood sample after Edwards refused; officers used a restraint chair and threatened a Taser but did not deploy it.
- Edwards was indicted for DUI with two prior DUI convictions (2003 and 2012), making the 2013 offense a third-offense DUI for enhancement.
- Edwards moved to suppress the warrantless, nonconsensual blood draw and separately moved to strike his 2003 conviction from the part II information, arguing that his 2003 guilty plea was not voluntary, knowing, and intelligent.
- The circuit court denied both motions (its reasoning referenced a “good faith” warrant exception), and Edwards was convicted at trial of having a blood-alcohol concentration of 0.08% or more and adjudicated a third-offense DUI.
- On appeal the Supreme Court reviewed (1) whether the compelled, warrantless blood draw violated the Fourth Amendment and whether suppression was required, and (2) whether the 2003 conviction could be used for enhancement given Boykin-related voluntariness concerns.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether warrantless, compelled blood draw admissible | Edwards: compelled nonconsensual blood draw violated Fourth Amendment and state constitution; suppression required | State: implied-consent statute and special-needs/exigent-circumstances or legislative conditioning of driving privilege justify warrantless draw; alternatively, evidence admissible under good-faith reliance on then-binding state precedent | Court: Warrantless compelled blood draws violate the Fourth Amendment absent a well-delineated exception; but suppression not required here because officer reasonably relied on binding South Dakota precedent at the time—good-faith exception to exclusionary rule applies (per Davis) |
| Whether SDCL 32-23-10 (implied consent) permits warrantless compelled blood draws | Edwards: statutory scheme cannot constitutionally eliminate warrant requirement for compelled intrusions | State: statute conditions driving privilege on consent and authorizes withdrawal after arrest | Court: Legislative conditioning and special-needs do not justify compelled, warrantless blood draws; statute cannot override Fourth Amendment; state’s argument rejected (citing Fierro) |
| Whether suppression is appropriate remedy | Edwards: exclusion required for deterrence of future violations | State: suppression unwarranted because officer relied on longstanding state precedent (per Schmerber/Hartman) | Court: Under Davis, suppression unnecessary because officer acted in objectively reasonable reliance on binding state precedent extant when blood was drawn (pre-McNeely) |
| Whether 2003 conviction valid for enhancement | Edwards: 2003 guilty plea not knowing/voluntary; Boykin rights not personally advised; plea infirm and must be stricken | State: court record shows advisals; State met burden to show valid judgment; presumption of regularity | Court: Record shows group advisement and individual canvass; Boykin rights and consequences were explained and Edwards affirmed understanding — conviction stands for enhancement |
Key Cases Cited
- Schmerber v. California, 384 U.S. 757 (recognizing blood draws as Fourth Amendment searches and discussing exigent-circumstances analysis)
- Missouri v. McNeely, 133 S. Ct. 1552 (2013) (rejected per se exigency based solely on alcohol dissipation; exigency must be determined case-by-case)
- Davis v. United States, 131 S. Ct. 2419 (2011) (good-faith reliance on binding precedent precludes suppression under exclusionary rule)
- United States v. Leon, 468 U.S. 897 (1984) (foundation for good-faith exception to exclusionary rule)
- Herring v. United States, 555 U.S. 135 (2009) (exclusionary rule’s deterrence rationale and limits)
- State v. Hartman, 256 N.W.2d 131 (S.D. 1977) (South Dakota’s prior interpretation that alcohol dissipation created per se exigent circumstance for warrantless blood draws)
- State v. Fierro, 853 N.W.2d 235 (S.D. 2014) (rejected State’s argument that SD implied-consent statute authorizes compelled warrantless blood draws and analyzed constitutional limits)