State v. Palmer

Summary

The Maine Supreme Judicial Court affirmed Rowe L. Palmer’s convictions for aggravated operating under the influence and aggravated assault. The court held that probable cause existed to obtain a blood sample based on Palmer’s role in a serious collision and his admission that he had consumed alcohol. It further held that the impending surgery and resulting limited opportunity to obtain a warrant created exigent circumstances justifying the warrantless blood draw.

Holdings

1. Probable cause existed because the unexplained collision caused by Palmer crossing the centerline, combined with his admission that he had consumed alcohol before the accident, supported a prudent and cautious person's belief that Palmer had operated under the influence.
2. Exigent circumstances justified the warrantless hospital blood draw because, after probable cause arose, Palmer's impending surgery and the prior passage of time created a now-or-never situation in which waiting to obtain a warrant would significantly undermine the efficacy of the blood test.

Questions Presented

1. Whether the officer had probable cause to believe Palmer had operated under the influence when the hospital blood sample was obtained.
2. Whether exigent circumstances justified obtaining the hospital blood sample without a warrant.

Disposition

affirmed