State v. Walker
2011 UT 53
| Utah | 2011Background
- Ms. Walker was involved in a multi-vehicle collision on Bacchus Highway; one driver died and another was seriously injured.
- Detectives sought a blood-draw warrant after interviewing Walker; they believed she may have been impaired and learned her license was revoked for alcohol and she was interlock-restricted.
- Affidavit alleged Walker crossed the center line, caused injuries/death, could not remember the crash, and drove a Boss’s vehicle, suggesting lack of an interlock device.
- Magistrate issued a warrant authorizing blood draw based on probable cause; blood later tested positive for methamphetamine/amphetamine.
- District court found no probable cause for the Warrant but applied the good-faith exception under United States v. Leon to deny suppression.
- Walker pleaded to certain charges with a conditional right to appeal suppression ruling; the Utah Court of Appeals certified the case and the Supreme Court accepted review.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether magistrate had probable cause to search Walker's blood | Walker | Walker | Probable cause existed; magistrate had substantial basis to believe evidence would be found in Walker's blood |
| Whether Utah's exclusionary rule has a good-faith exception | Walker | State | Court did not need to decide beyond probable cause; good-faith issue not reached on direct appeal |
| Whether alternative grounds require exclusionary-rule analysis under state constitution | Walker | State | Not necessary to decide; probable cause affirmed on alternative ground |
Key Cases Cited
- United States v. Leon, 468 U.S. 897 (U.S. 1984) (good faith exception to suppression standard)
- State v. Norris, 2001 UT 104 (Utah 2001) (probable cause standard under Utah law)
- Mapp v. Ohio, 367 U.S. 643 (U.S. 1961) (exclusionary rule applied to state courts)
- Adams v. New York, 192 U.S. 585 (U.S. 1904) (historical context of admissibility of illegally obtained evidence)
- Boyd v. United States, 116 U.S. 616 (U.S. 1886) (narrow discussion on exclusionary remedies; limited to testimonial evidence)
- State v. Aime, 62 Utah 476, 220 P.704 (Utah 1923) (early Utah stance on admissibility unaffected by illegality of means)
- State v. Fair, 10 Utah 2d 365, 353 P.2d 615 (Utah 1960) (no exclusionary rule under Utah Constitution precedent)
- State v. Larocco, 794 P.2d 460 (Utah 1990) (adoption of Utah exclusionary rule)
- State v. Thompson, 810 P.2d 415 (Utah 1991) (adoption of exclusionary rule under Utah Constitution)