State v. Martines
184 Wash. 2d 83
| Wash. | 2015Background
- Martines drove erratically, collided, and exhibited signs of impairment (stumbling, slurred speech, red eyes, alcohol odor); officers arrested him for suspected DUI.
- Trooper obtained a warrant authorizing extraction of a blood sample, stating the sample "may be tested to determine . . . blood alcohol level and to detect the presence of any drugs." Warrant itself authorized blood extraction but did not expressly state testing.
- A hospital drew Martines’s blood under the warrant; the state toxicology lab tested it for alcohol and drugs. Tests showed BAC around 0.061–0.062 (toxicologist estimated higher earlier) and presence of diazepam and nordiazepam.
- Martines moved to suppress evidence of drug testing, arguing no probable cause to test for drugs specifically and that testing is a separate search requiring express authorization. Trial court denied suppression; jury convicted Martines of felony DUI.
- The Court of Appeals reversed, holding blood testing is a separate search requiring express authorization and the warrant authorized only the draw. The State appealed to the Washington Supreme Court.
Issues
| Issue | Martines’s Argument | State’s Argument | Held |
|---|---|---|---|
| Whether probable cause existed to test the blood for drugs (distinct from alcohol) | Probable cause to test for drugs was not shown; affidavit lacked facts indicating drug intoxication | Probable cause to suspect impairment may include alcohol, drugs, or both; affidavit supported testing for intoxicants generally | Probable cause was sufficient: officer could reasonably suspect impairment from alcohol, drugs, or both, so testing for drugs was authorized |
| Whether a warrant authorizing blood extraction equally authorizes testing the sample | Testing is a separate, privacy-intrusive search that requires explicit authorization; the warrant only authorized drawing blood | A blood-draw warrant necessarily includes testing for the suspected crime’s evidence (intoxicants); commonsense reading permits testing within probable cause bounds | Warrant authorizing blood extraction implicitly authorized testing the sample for intoxicants; separate express authorization not required |
| Particularity: whether the warrant was too vague and permitted exploratory rummaging of the blood sample | Warrant lacked particularity as to what analyses were permitted, risking unlimited searches of the sample | Warrant’s purpose (to obtain evidence of DUI) limits permissible testing; testing to detect intoxicants is within the warrant’s scope | Warrant met particularity requirements when read in commonsense/practical manner; testing for intoxicants was within scope |
| Scope of the search: whether testing exceeded the warrant’s bounds | N/A (focused on lack of authorization) | Even if warrant silent, testing was reasonable and confined to DUI-related analysis | Execution did not exceed the warrant; testing for intoxicants was within the authorized seizure of blood |
Key Cases Cited
- Skinner v. Railway Labor Exec. Ass’n, 489 U.S. 602 (1989) (blood testing involves privacy interests beyond bodily penetration)
- State v. Perrone, 119 Wn.2d 538 (1992) (particularity requirement and purposes of warrant description)
- State v. Riley, 121 Wn.2d 22 (1993) (warrants must describe with particularity; practical interpretation)
- State v. Grenning, 169 Wn.2d 47 (2010) (lawful seizure of evidence includes testing/examination to ascertain evidentiary value)
- State v. Baldwin, 109 Wn. App. 516 (2001) (if alcohol is ruled out, separate probable cause required to draw blood for drugs)