State v. Travis William Coats
Background
- Coats rear-ended a stopped minivan; officers observed lethargy, slurred speech, and poor coordination.
- Officer administered field sobriety tests and two breathalyzer samples; breath tests showed no alcohol.
- After being Mirandized, Coats invoked his right to remain silent; later the officer asked if Coats would go to the hospital for a blood draw and Coats orally agreed.
- At the hospital the officer read a written blood-draw authorization aloud; Coats signed the form and a nurse drew blood, which tested positive for multiple drugs; Coats was charged with felony DUI.
- Coats moved to suppress post-Miranda statements and the warrantless blood results; the court suppressed the statements but denied suppression of the blood test results, and Coats entered a conditional guilty plea reserving the suppression issue.
Issues
| Issue | Coats' Argument | State's Argument | Held |
|---|---|---|---|
| Whether Coats gave voluntary actual consent to warrantless blood draw | Consent was involuntary due to police deceit and Coats’ vulnerable state | Consent was voluntary; no coercion or deception and Coats never revoked implied consent | Consent was voluntary; court affirmed denial of suppression |
| Whether implied-consent revocation barred warrantless draw | Argued he revoked implied consent | State contended he never revoked implied consent | Not reached (dispositive ruling on actual consent) |
| Whether blood results are fruit of police misconduct (Wong Sun) | Contended results were poisonous fruit of misconduct | Argued doctrine inapplicable | Not reached (dispositive ruling on actual consent) |
| Standard of review for suppression factual findings | N/A (procedural) | N/A | Appellate court accepts trial court’s factual findings if supported by substantial evidence; reviews legal application de novo |
Key Cases Cited
- Miranda v. Arizona, 384 U.S. 436 (Miranda rights and custodial interrogation)
- Schmerber v. California, 384 U.S. 757 (blood draws are searches under Fourth Amendment)
- Schneckloth v. Bustamonte, 412 U.S. 218 (voluntariness of consent judged under totality of circumstances)
- Wong Sun v. United States, 371 U.S. 471 (fruit of the poisonous tree doctrine)
- Missouri v. McNeely, 569 U.S. 141 (warrantless blood draws presumptively unreasonable)