United States v. Manubolu, 13 F.4th 57

Around 2:48–3:00 A.M. on Aug. 31, 2019, a single‑car crash in Acadia National Park killed three passengers; Praneeth Manubolu was the driver and exhibited signs of intoxication.
EMTs treated Manubolu and transported him to the hospital; officers did not perform field sobriety or breath tests because of injuries and lack of portable equipment.
Ranger Dominy and Bar Harbor PD officers concluded probable cause existed for a BAC test; Officer Hardy ordered a warrantless blood draw at about 4:24 A.M. (~90 minutes after the crash), invoking a then‑existing Maine statute.
National Park Service regulation and Supreme Court precedent require exigent circumstances to justify warrantless blood draws in federal parks; Ranger Dominy attempted to contact AUSAs but had delayed and limited responses.
The district court suppressed the warrantless blood result; the government appealed. The First Circuit reversed, holding exigent circumstances existed under the totality of the circumstances (dissipating BAC, investigative burdens from a fatal crash, limited personnel, and slow warrant procedures).

Issue	Manubolu's Argument	Government's Argument	Held
Whether exigent circumstances justified a warrantless blood draw	No exigency — BAC dissipation alone is not per se; officers had time and could have sought a warrant; AUSAs’ responsiveness and procedures cannot create exigency	Yes — dissipating BAC plus pressing investigative/health needs, limited personnel, and protracted warrant processes made delay likely to destroy evidentiary value	Reversed suppression: exigency existed under the totality of circumstances; warrantless draw was reasonable
Whether officers’ subjective intent to rely on state statute controls the analysis	District court emphasized officers relied on Maine law, showing they did not intend to seek a warrant	Subjective intent is irrelevant; objective, reasonable‑officer judgment governs exigency inquiry	Court: subjective intent not dispositive; apply objective totality‑of‑circumstances test
Whether cumbersome warrant procedures can be weighed (and whether that creates a per se rule)	Allowing procedure delays to justify searches risks a per se exception and would undermine McNeely	Practical delays in warrant procurement (especially at 3 A.M.) are relevant to exigency; consideration does not create a per se rule	Court: warrant‑process delays are a legitimate factor; decision does not announce a per se rule — analyze on the facts

Schmerber v. California, 384 U.S. 757 (establishing exigency in the context of a serious crash and medical exigencies)
Missouri v. McNeely, 569 U.S. 141 (holding BAC dissipation alone is not a per se exigency; analyze totality and warrant‑process delays)
Mitchell v. Wisconsin, 139 S. Ct. 2525 (plurality: frames exigency as a spectrum; dissipation plus other pressing needs can justify warrantless draws)
Birchfield v. North Dakota, 136 S. Ct. 2160 (blood draws are searches generally requiring a warrant; breath tests treated differently)
Kentucky v. King, 563 U.S. 452 (exigent‑circumstances framework for warrant exceptions)
Illinois v. McArthur, 531 U.S. 326 (recognizing exceptions to the warrant requirement)
Brigham City v. Stuart, 547 U.S. 398 (subjective intent of officers does not control Fourth Amendment exigency analysis)