State v. Medicine, 865 N.W.2d 492

Traffic stop of Medicine on May 3, 2014, 8:06 p.m., in Rapid City; DUI arrest after field sobriety tests.
DUI advisement card informed Medicine of implied consent to blood withdrawal and asked for submission to withdrawal.
Medicine orally consented to blood draw; no verbal objection or resistance.
Circuit court suppressed the blood test, finding the consent involuntary.
State appealed, arguing consent was voluntary under totality of circumstances.
Court analyzes voluntariness under Fourth Amendment and state statutory framework; blood draw is a search requiring warrant or valid exception.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Was Medicine's consent voluntary?	Medicine (State) argued consent was voluntary under totality of circumstances.	Medicine argued coercive card language and custodial arrest rendered consent involuntary.	Consent involuntary; suppression affirmed.

Schneckloth v. Bustamonte, 412 U.S. 218 (1973) (coercion and voluntariness must be examined under totality of circumstances)
Bumper v. North Carolina, 395 U.S. 543 (1968) (consent cannot validate a search obtained by coercive means)
Florida v. Royer, 460 U.S. 491 (1983) (consent must be freely given, not coerced by authority)
Ohio v. Robinette, 519 U.S. 33 (1996) (establishes that right to consent may be clarified without coercion)
United States v. Drayton, 536 U.S. 194 (2002) (police questions can be coercive; need for voluntary consent)
United States v. Watson, 423 U.S. 411 (1976) (custody alone is not enough to imply coercion; context matters)
Missouri v. McNeely, 133 S. Ct. 1552 (2013) (blood draw as a search requiring warrant or valid exception)