State v. Chernobieff

Summary

The Idaho Supreme Court affirmed the denial of Daniel Chernobieff’s motion to suppress evidence from a warrantless blood draw in a DUI case. The court held that, under the totality of the circumstances, exigent circumstances justified the draw after law enforcement made unsuccessful efforts to obtain a warrant and alcohol was dissipating. The court also noted the State’s obligation to maintain a functional warrant-obtaining system.

Holdings

1. Under the totality of the circumstances, the dissipation of alcohol, the lateness of the hour, the delays in the warrant process, and the prosecutor's good-faith but unsuccessful efforts to reach the on-call magistrate established exigent circumstances sufficient to justify the warrantless blood draw.
2. Delay caused by a defendant's exercise of constitutional rights may not be considered in determining whether exigent circumstances justified a warrantless search.

Questions Presented

1. Whether exigent circumstances under the Fourth Amendment and Article I, section 17 of the Idaho Constitution justified obtaining Chernobieff's blood without a warrant.
2. Whether the district court erred in affirming the magistrate court's denial of the motion to suppress.

Disposition

affirmed