139 So. 3d 519
La.2014Background
- Three-occupant truck collided with another vehicle, killing the other driver; survivors (including defendant) transported to hospitals.
- Police arrived after first responders; initially could not identify which occupant had been driving.
- One officer ran the truck’s plate at the scene and learned defendant was the registered owner before the blood draw was authorized.
- Two other occupants were conscious; one consented to a blood draw; defendant’s blood was drawn at the hospital without his express consent.
- Defendant was convicted of vehicular homicide; the trial court denied his motion to suppress the blood-alcohol test; the First Circuit reversed; the State sought review.
- Louisiana Supreme Court reinstated conviction, holding the warrantless blood draw was justified under the collective-knowledge and owner-driver presumptions.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether police had reasonable grounds to order blood testing of an unconscious occupant after a fatal crash | State: Officers had reasonable grounds because the team knew there was a fatality, the truck caused it, and defendant was the truck’s registered owner | Weber: Police lacked reasonable grounds; one in three chance owner was driver is insufficient | Held: Yes — collective knowledge + owner-driver inference gave reasonable grounds to authorize draw |
| Whether collective knowledge of officers can supply probable cause when authorizing a blood draw | State: Knowledge of one officer (plate check) can be imputed to the officer who authorized the draw because they acted as a coordinated team | Weber: The authorizing officer did not personally know ownership info, so he lacked requisite belief | Held: Collective knowledge of investigating team may be imputed; communication need not be proven if officers were functioning as a team |
| Whether exigency (evanescent BAC) affects reasonableness of warrantless blood draws in fatal crashes | State: Rapid decline of BAC makes prompt testing essential and supports reasonableness | Weber: Argued statutory scheme already addresses testing; challenge focused on identity of driver, not exigency | Held: Evaporative nature of BAC supports urgency and necessity to preserve evidence; reinforces reasonableness |
| Whether the trial court erred in denying suppression and whether conviction should be reinstated | State: Trial court properly denied motion to suppress; blood test admissible; conviction valid | Weber: Appellate court erred in reversing suppression ruling | Held: Trial court ruling reinstated; conviction and sentence for vehicular homicide reinstated |
Key Cases Cited
- State v. Landry, 729 So.2d 1019 (La. 2000) (probable cause may rest on collective knowledge of officers)
- United States v. Klein, 93 F.3d 698 (10th Cir. 1996) (collective knowledge doctrine supports probable cause)
- United States v. Gillette, 245 F.3d 1032 (8th Cir. 2001) (when officers function as a team, knowledge may be imputed among them)
- State v. Thompson, 842 So.2d 330 (La. 2003) (probable-cause standard and fair-probability formulation)
- State v. Tozier, 905 A.2d 836 (Me. 2006) (officer may reasonably infer driver is vehicle’s registered owner absent contrary indications)
- United States v. Banks, 514 F.3d 769 (8th Cir. 2008) (probable cause judged on combined knowledge of a search team)