State v. Saunders
2017 Ohio 7348
| Ohio Ct. App. | 2017Background
- On Jan. 17, 2016 Tony Saunders was injured in a one-vehicle crash and taken to Morrow County Hospital; witnesses and a trooper smelled alcohol on him and observed signs of intoxication.
- Hospital personnel drew blood for medical treatment; lab tests later showed alcohol present.
- Trooper Sutterluety submitted a Request for Release of Health Care Provider Records under R.C. 2317.02(B)(2) and obtained Saunders’ blood-alcohol test results without a warrant.
- Saunders was charged with OVI offenses and moved to suppress the hospital lab results, arguing the records were obtained via a warrantless search in violation of the Fourth Amendment.
- The trial court granted the motion to suppress; the State appealed, arguing the statutory scheme authorized the records release.
- The appellate court affirmed suppression, holding the statutes do not authorize a warrantless search of medical test results when no warrant exception applies.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether law enforcement may obtain hospital blood-test results under R.C. 2317.02/2317.022 without a warrant | Statutes permit police to request and obtain medical test results from health care providers without a warrant | Police-requested production of medical test results is a warrantless search violating the Fourth Amendment and must be suppressed | The court held the statutes do not authorize a warrantless search of a patient's medical test results; suppression affirmed when no warrant or exigent exception exists |
Key Cases Cited
- Whalen v. Roe, 429 U.S. 589 (1977) (government storage/disclosure of medical data raises privacy concerns but constitutionality depends on risk of public disclosure)
- Ferguson v. City of Charleston, 532 U.S. 67 (2001) (compelled drug tests for nonmedical purposes implicated Fourth Amendment protections)
- Missouri v. McNeely, 569 U.S. 141 (2013) (warrantless blood draws in DUI cases require case‑by‑case exigency analysis; BAC evidence alone does not create per se exigency)
- McDonald v. United States, 335 U.S. 451 (1948) (warrant requirement cannot be excused without showing exigent circumstances)
- Stone v. City of Stow, 64 Ohio St.3d 156 (1992) (lists recognized exceptions to the warrant requirement under Ohio law)
- City of Xenia v. Wallace, 37 Ohio St.3d 216 (1988) (burden on the state to justify a warrantless search under an exception to the Fourth Amendment)