State v. Price
270 P.3d 527
Utah2012Background
- Mr. Price allegedly caused a fatal accident and was suspected of intoxication after an odor of alcohol at the scene.
- A portable breath test at the scene indicated alcohol, leading to a request and consent to go to the police station for further testing.
- Mr. Price initially refused a blood test; an affidavit supported a warrant to seize his blood for testing without specifying tests.
- Two vials of blood were collected and sent to a lab to test for alcohol, cocaine, THC, morphine, and methamphetamine; THC tested positive.
- The district court held the blood lawfully seized and tested for contraband; Mr. Price’s motion to suppress was denied; he appealed by interlocutory review.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether THC testing exceeded the warrant scope | Price argues testing for THC exceeded the warrant’s scope, which covered alcohol only. | Price contends the testing violated Fourth Amendment rights because it sought non-specified tests. | THC testing did not violate Fourth Amendment scope; permissible once blood lawfully seized. |
| Whether there is a legitimate privacy interest in contraband within blood | Price claims a privacy interest in non-contraband blood contents and private medical facts. | State argues no privacy interest in contraband contents once blood is lawfully seized. | No legitimate privacy interest in contraband contents; testing for THC is not a Fourth Amendment intrusion. |
Key Cases Cited
- State v. Tripp, 227 P.3d 1251 (Utah Supreme Court, 2010) (standard of review for suppression rulings; factual findings reviewed clearly erroneous)
- Caballes v. Illinois, 543 U.S. 404 (U.S. 2005) (drug-sniffing dog reveals only presence of contraband; no privacy intrusion)
- Skinner v. Ry. Labor Execs' Ass'n, 489 U.S. 602 (U.S. 1989) (chemical analysis of blood can reveal private medical facts)
- Kyllo v. United States, 533 U.S. 27 (U.S. 2001) (two-part Katz privacy framework; tests revealing private details implicate privacy interests)
- United States v. Jacobsen, 466 U.S. 109 (U.S. 1984) (two-part private expectation of privacy standard for Fourth Amendment)
- City of Ontario v. Quon, 130 S. Ct. 2619 (U.S. Supreme Court, 2010) (Fourth Amendment protects privacy rights; context of searches and surveillance)