State v. Hatfield, 912 N.W.2d 731

In December 2014 deputies stopped Steven Hatfield for speeding, detected alcohol odor, observed signs of impairment, and arrested him for DUI.
At the hospital Hatfield was given and signed Nebraska’s "Post Arrest Chemical Test Advisement" stating he was required to submit to a blood test and that refusal was a separate crime; a nurse drew blood and Hatfield cooperated.
Blood results showed alcohol above the legal limit; Hatfield was convicted in county court and the conviction was later enhanced as a second offense.
On intermediate appeal to the district court, after briefing concluded the U.S. Supreme Court decided Birchfield v. North Dakota; the district court relied on Birchfield to hold the warrantless blood draw unlawful and reversed the conviction without addressing voluntariness or the good faith exception.
The State filed an exception appeal to the Nebraska Supreme Court seeking review of the district court’s reversal; the Supreme Court considered whether the good faith exception applied to pre-Birchfield warrantless blood draws.
The Nebraska Supreme Court held the good faith exception applied, sustained the State’s exception, reversed the district court, and remanded for further proceedings.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the district court erred in vacating conviction without addressing (1) voluntariness of consent and (2) applicability of the good faith exception to evidence obtained under pre-Birchfield implied-consent law	State: District court should have considered whether good faith exception applies and whether consent was voluntary before suppressing blood results	Hatfield: Birchfield rendered warrantless blood draws unconstitutional such that the blood evidence was inadmissible; district court properly reversed	The court held the good faith exception applies to pre-Birchfield warrantless blood draws under Nebraska’s implied-consent statute; reversal by district court was error and case remanded (voluntariness not decided)

Birchfield v. North Dakota, 136 S. Ct. 2160 (2016) (addressed constitutionality of warrantless breath and blood tests and limits on implied-consent criminal penalties)
State v. Hoerle, 297 Neb. 840 (2017) (Nebraska applied good faith exception to pre-Birchfield warrantless blood draw)
State v. Thalken, 299 Neb. 857 (2018) (procedural discussion of appeals from county to district court as intermediate appellate review)
State v. Tyler, 291 Neb. 920 (2015) (describing exclusionary rule as judicially created remedy for Fourth Amendment violations)
State v. Hill, 288 Neb. 767 (2014) (discussion of exclusionary rule’s deterrence purpose)