Commonwealth of Kentucky v. Christopher B. Stokes

Summary

The Kentucky Court of Appeals vacated and remanded the Todd Circuit Court’s suppression order excluding blood-test results obtained from Christopher B. Stokes after a fatal motor-vehicle accident. The court held that voluntariness of consent following an implied-consent warning must be evaluated under the totality of the circumstances without presumptions or a requirement that the warning be attenuated or overcome. On remand, the circuit court must also consider the good-faith exception to the exclusionary rule.

Holdings

1. Whether consent to a blood draw was voluntary must be determined from the totality of all the circumstances, without a presumption that the implied-consent warning is controlling or must be attenuated or overcome.
2. The circuit court must consider the good-faith exception to the exclusionary rule as a matter of law based on the facts ultimately found.
3. Vacatur and remand were required because the record and factual findings were insufficient to conduct a proper totality-of-the-circumstances analysis and to apply the good-faith exception.

Questions Presented

1. Whether the circuit court improperly treated the Kentucky implied-consent warning as presumptively coercive or as a factor that the Commonwealth had to overcome, rather than evaluating voluntariness under the totality of all circumstances.
2. Whether the suppression court was required to consider the good-faith exception to the exclusionary rule in determining whether the blood-test results should be excluded.
3. Whether the incomplete factual record required vacatur and remand for further evidentiary development and factual findings.

Disposition

vacated