State v. Meitler
347 P.3d 670
Kan. Ct. App.2015Background
- Feb 10, 2012: Meitler crossed the centerline in a two-vehicle crash that killed the other driver; Meitler was seriously injured and unconscious at the hospital.
- Troopers Morris and Maier directed hospital personnel to draw Meitler’s blood after relying on K.S.A. 2011 Supp. 8-1001(b)(2) (implied-consent provision treating certain fatal/serious-accident situations as probable cause).
- Blood tested positive for methamphetamine and marijuana; Meitler was charged with involuntary manslaughter, aggravated battery, and DUI.
- Meitler moved to suppress the blood results, relying on State v. Declerck (Kansas Ct. App.) holding that § 8-1001(b)(2) was unconstitutional because a traffic infraction plus injury/fatality, without more, does not constitute probable cause.
- The district court suppressed the blood evidence (finding Declerck controlling and concluding the good-faith exception did not apply); the State appealed.
- The Kansas Court of Appeals reversed, holding officers reasonably relied in good faith on the then-valid statute and the exclusionary rule did not bar the evidence; a dissent argued legislative abdication justified suppression.
Issues
| Issue | Plaintiff's Argument (Meitler) | Defendant's Argument (State) | Held |
|---|---|---|---|
| Whether K.S.A. 2011 Supp. 8-1001(b)(2) supplies constitutionally sufficient probable cause for a blood draw after a fatal/serious crash | Statute unconstitutional as applied: traffic infraction + injury/fatality, without more, does not establish probable cause | Statute was valid prior to Declerck; in any event officers relied on it | Court assumes Declerck’s unconstitutionality ruling applies but proceeds to next issue (good-faith) |
| Whether evidence should be suppressed under the exclusionary rule despite statute being later declared unconstitutional | Suppress: search violated Fourth Amendment; exclusionary rule should apply | Admit: officers acted in objectively reasonable good-faith reliance on statute before Declerck | Held: good-faith exception applies; evidence admissible |
| Whether implied consent (driver unconscious) justified the blood draw without separate probable cause | Implied consent does not cure Fourth Amendment defect; consent must be voluntary and informed | State: unconscious driver deemed to have impliedly consented under statute | Court did not base decision on implied-consent defense; focused on good-faith reliance instead |
| Whether the Kansas Legislature “wholly abandoned” its duty (Krull exception) so good-faith exception is unavailable | Legislature redefined probable cause to evade Fourth Amendment; exclusionary rule should apply | Legislature did not wholly abandon duty; amendment was narrow, had supporting testimony and similar statutes considered elsewhere | Held: no showing of wholesale legislative abandonment; Krull exception inapplicable |
Key Cases Cited
- Schmerber v. California, 384 U.S. 757 (permits warrantless blood draw where officer has probable cause and exigency exists)
- Illinois v. Krull, 480 U.S. 340 (good-faith exception for reliance on statute unless statute is clearly unconstitutional or legislature wholly abandoned its duty)
- United States v. Leon, 468 U.S. 897 (good-faith exception for reliance on a judge-issued warrant)
- State v. Declerck, 49 Kan. App. 2d 908 (Kan. Ct. App.) (held K.S.A. 2011 Supp. 8-1001[b][2] unconstitutional under the Fourth Amendment)
- State v. Daniel, 291 Kan. 490 (Kan. 2010) (endorses Krull framework in Kansas)