Tony Harrell-MacNeil v. State, 07-15-00009-CR

Appellant Tony Harrell-MacNeil was charged with DWI and moved to suppress blood-test results obtained under a search warrant.
The issued warrant directed transporting Appellant to a McLennan County hospital for the blood draw.
Instead, a licensed vocational nurse drew the blood at the McLennan County Jail using recognized procedures and in a sanitary place.
Appellant argued suppression was required because officers failed to comply with the warrant term specifying a hospital draw.
The trial court denied the motion to suppress, reasoning the draw complied with medically acceptable procedures and relied on precedent rejecting hyper‑technical challenges to warrant execution.
Appellant pleaded guilty but reserved the right to appeal the suppression ruling.

Issue	Plaintiff's Argument	Defendant's Argument	Held
Whether the trial court erred by denying suppression when the warrant required a hospital blood draw but blood was taken at jail	The warrant explicitly required a hospital draw; noncompliance is a blatant disregard that mandates suppression	The hospital requirement was boilerplate; Fourth Amendment reasonableness controls — blood taken by qualified personnel in sanitary conditions is acceptable	Trial court did not abuse discretion; no prejudice shown and the draw was reasonable

Schmerber v. California, 384 U.S. 758 (1966) (blood draws are searches; methods must satisfy Fourth Amendment reasonableness)
State v. Johnson, 336 S.W.3d 649 (Tex. Crim. App. 2011) (blood drawn according to acceptable medical practices satisfies reasonableness)
Martinez v. State, 348 S.W.3d 919 (Tex. Crim. App. 2011) (standard of review for suppression rulings is abuse of discretion)
Carmouche v. State, 10 S.W.3d 323 (Tex. Crim. App. 2000) (appellate review gives deference to trial court’s factual findings in suppression hearings)
Valtierra v. State, 310 S.W.3d 442 (Tex. Crim. App. 2010) (trial court’s ruling will be upheld if reasonably supported and correct on any legal theory)