Idaho v. Chernobieff

The question before the Supreme Court in this matter was whether exigent circumstances existed to justify a warrantless blood draw. Defendant-appellant Daniel Chenobieff argued the blood draw violated his constitutional protection against unreasonable searches and seizures and, consequently, that the district court erred in affirming the magistrate court’s denial of his motion to suppress the evidence obtained in the blood draw. The district court specifically pointed to the prosecutor’s attempt to obtain a warrant through the on-call magistrate who could not be reached. The district court also made reference to the delay resulting from Chernobieff's refusal to perform field sobriety tests, but in doing so the court erred. Any delay caused by Chernobieff's exercise of his Constitutional rights may not be considered. The court concluded that the magistrate considered the totality of circumstances and that the magistrate’s findings were supported by substantial evidence. The Supreme Court concurred with the district court. "Even excluding the delay related to the field sobriety tests, there was substantial evidence to support the magistrate’s findings. Therefore, we find that the district court did not err in affirming the denial of the motion to suppress the results of the blood draw." View "Idaho v. Chernobieff" on Justia Law