United States v. Lechliter
3 F. Supp. 3d 400
D. Maryland2014Background
- Following a June 23, 2012 traffic incident, Lechliter was arrested for DUI under 36 C.F.R. § 4.23(a)(1).
- Lechliter moved to suppress nonconsensual, warrantless blood testing, citing Missouri v. McNeely (2013).
- Judge DiGirolamo preliminarily ruled McNeely retroactive and in Brown denied suppression, prompting the instant appeal.
- Officer Harper testified that he arrested Lechliter, observed impairment, and waited for a tow truck and hospital blood draw without obtaining a warrant.
- There was no expedited warrant procedure in place at the time of arrest; the government argued for exigency and applied good faith to the blood draw.
- The district court granted suppression; the government appealed under Rule 58 and 18 U.S.C. § 3731.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether exigent circumstances justified the blood draw. | Lechliter argues McNeely negated warrantless draws absent special facts. | The government contends additional exigent factors existed and that good faith should save the evidence. | Exigency not established; but need for good faith analysis warranted remand. |
| Whether the good faith exception applies to the blood draw. | McNeely precludes good faith reliance on preexisting procedures. | Officer Harper acted on reasonable, ongoing policy expectations; McNeely misread; good faith should apply. | Good faith exception applies; suppression reversed and remanded. |
| Did Brown misapply McNeely by ignoring warrant procedures available at the time? | Brown misread McNeely’s emphasis on warrant procedures and expedited processes. | Brown correctly rejected warrantless draw absent expedited procedures. | Brown misapplied McNeely; not controlling; errors warrant reversal. |
| Should Reid and related authorities have preserved exigency findings for telephonic warrants? | Telephonic procedures do not change exigency. | Telephonic warrants can affect exigency timing. | Reid supports telephonic procedures not erasing exigency, aiding good-faith reliance. |
Key Cases Cited
- Schmerber v. California, 384 U.S. 757 (U.S. 1966) (exigent circumstances to obtain blood evidence in DUI stop)
- Missouri v. McNeely, 133 S. Ct. 1552 (U.S. 2013) (totality-of-circumstances exigency analysis; warrants may be expeditiously obtainable)
- United States v. Reid, 929 F.2d 990 (4th Cir. 1991) (Schmerber-based exigency; telephonic procedures contemplated)
- Davis v. United States, 131 S. Ct. 2419 (U.S. 2011) (exclusionary rule as deterrence; good-faith exception when conduct is reasonable)