The State v. Padgett, 329 Ga. App. 747

Padgett was indicted for DUI following a motorcycle crash and an ambulance transport to a hospital.
An officer administered an implied-consent warning and requested a blood test; Padgett consented.
Padgett’s blood was drawn by a hospital nurse, but the officer did not retain or forward the sample for State testing.
The hospital performed the analysis and recorded the result in Padgett’s medical record; the officer later sought a warrant to access the medical record.
The State conceded the hospital analysis did not meet OCGA 40-6-392(a)(1)(A) requirements, and the trial court granted the suppression motion, which the State appeals.
The appellate court affirmed, holding the hospital test was a State-administered test not complying with the statute, and the inevitable-discovery doctrine could not salvage admissibility.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether hospital blood analysis complies with OCGA 40-6-392(a)(1)(A).	Padgett	Padgett	No; statute applies to State-administered tests and hospital analysis failed requirements.
Whether inevitable discovery permits admission despite statutory noncompliance.	Padgett	Padgett	No; inevitable discovery cannot cure noncompliant State-administered testing.
Whether the test was State-administered for purposes of the statute.	Padgett	Padgett	Yes; test was state-administered because officer directed the blood test.

Perano v. State, 250 Ga. 704 (1983) (statutory framework for State-administered tests; purpose of procedures)
Oldham v. State, 205 Ga. App. 268 (1992) (tests at officer's request are State-administered; compliance critical)
Dixon v. State, 227 Ga. App. 533 (1997) (distinguishes officer-requested tests from hospital-initiated tests)
Carter v. State, 292 Ga. App. 322 (2008) (State-administered test must meet statutory requirements)
Nesbitt v. State, State v. Nesbitt, 305 Ga. App. 28 (2010) (inevitable discovery analysis in context of noncompliant testing)