Court: Supreme Court of the United States; February 25, 1957; Federal Supreme Court; Federal Appellate Court
Mr. Justice Clark provided the Court's opinion regarding a case involving a petitioner who, after a collision in New Mexico that resulted in the deaths of three individuals and serious injury to himself, was found to have a blood alcohol content of .17%. A whiskey bottle was discovered in his pickup, and while unconscious, a blood sample was taken without his consent, which later contributed to his conviction for involuntary manslaughter. Despite objections, the blood test results were admitted as evidence, and the petitioner did not appeal the conviction.
Later, he sought release through a writ of habeas corpus, claiming that the blood test violated his due process rights under the Fourteenth Amendment, arguing it constituted an unreasonable search and seizure under the Fourth Amendment and violated his Fifth Amendment rights against self-incrimination. However, the Supreme Court of New Mexico denied the writ, and the U.S. Supreme Court granted certiorari to assess the due process implications of the conviction.
The Court noted that evidence obtained in violation of the Fourth Amendment must be excluded in federal cases, as established in Weeks v. United States, but New Mexico had not adopted this exclusionary rule. The petitioner’s argument that the violations should extend protections of the Bill of Rights through the Due Process Clause was countered by Wolf v. Colorado, which denied such an extension. The Court further examined the petitioner’s assertion that the actions of state officers violated a sense of justice, referencing Rochin v. California, where egregious conduct by law enforcement led to a conviction being overturned. However, the Court found no comparable misconduct in the petitioner’s case, thus upholding the admissibility of the blood test results and the conviction.
The distinction made in the document centers on the non-offensive nature of blood sample collection when conducted by a physician, even if the individual is unconscious. The lack of conscious consent does not inherently violate constitutional rights. Due process is evaluated based on community standards of decency and fairness, rather than individual sensitivities. Blood testing has become a common procedure in various societal contexts, including military service and marriage applications, and many states have legislated the admissibility of such tests in evidence.
The court concludes that a properly administered blood test by a qualified technician does not shock the conscience or offend justice. While indiscriminate blood collection could be considered brutal, the specific test in question adheres to medical standards and is scientifically reliable for measuring blood alcohol content. The pressing issue of highway safety necessitates modern scientific methods to combat intoxicated driving, which poses significant risks. The societal interest in accurately determining intoxication and potentially proving innocence outweighs the individual’s right to bodily inviolability in this context.
The judgment affirms the denial of the writ of habeas corpus sought by the petitioner, reflecting a broader understanding that drivers implicitly consent to blood tests as a societal measure to enhance road safety and mitigate the dangers of impaired driving.
In Kansas, operating a motor vehicle on public highways constitutes consent to undergo chemical testing (breath, blood, urine, or saliva) to assess blood alcohol content. If a driver, arrested for operating a vehicle under the influence, refuses the test after the officer has reasonable grounds for the arrest, the officer must report this refusal, leading to suspension of the driver's permit. Forty-seven states utilize chemical tests for determining intoxication in DUI cases, with twenty-three states implementing them by statute, largely based on the Uniform Vehicle Code. Presence of a specific blood alcohol percentage creates a presumption of intoxication. States such as Arizona, Delaware, Georgia, and others have statutory provisions for such testing, while some states allow tests through court approval without statutory authority. The widespread acceptance of chemical tests undermines claims of their offensiveness, as courts have not reversed DUI convictions based on blood tests. Blood withdrawal for testing is commonly regulated, requiring a physician for blood collection and a competent technician for analysis. Municipalities typically adhere to these procedures to ensure compliance and safety.
