Utah Supreme Court
Can police test blood for drugs beyond what's specified in a warrant? State v. Price Explained
Summary
Price was involved in a fatal car accident and consented to a breath test showing alcohol, but refused a blood test. Police obtained a warrant to test his blood for alcohol, but the lab also tested for THC and other controlled substances, with THC testing positive. Price moved to suppress the THC evidence, arguing the warrant only authorized alcohol testing.
Analysis
In State v. Price, the Utah Supreme Court addressed whether police can test lawfully seized blood for controlled substances beyond those specified in a search warrant, establishing important precedent for Fourth Amendment protections in blood testing cases.
Background and Facts
Price was involved in a fatal car accident where he failed to yield and killed a teenage passenger. At the scene, a deputy smelled alcohol on Price’s breath and administered a portable breath test, which was positive. When Price refused a blood test at the station, police obtained a warrant to seize his blood for testing to determine his blood-alcohol level. The warrant specified only “blood” without detailing what tests could be conducted. The crime lab tested the blood for alcohol, cocaine, THC, morphine, and methamphetamine, with results positive for THC.
Key Legal Issues
Price moved to suppress the THC evidence, arguing that testing for THC exceeded the warrant’s scope since probable cause was based only on suspected alcohol impairment. The central question was whether individuals retain a reasonable expectation of privacy in contraband found in lawfully seized blood samples.
Court’s Analysis and Holding
The Utah Supreme Court applied the two-part Katz test for Fourth Amendment protection and the U.S. Supreme Court’s ruling in Illinois v. Caballes. The court held that individuals have no legitimate privacy interest in contraband contents of their blood. Following Caballes, the court reasoned that “any interest in possessing contraband cannot be deemed ‘legitimate.'” The court distinguished between contraband detection and tests that might reveal private medical information, noting that THC testing revealed only contraband presence, not legitimate private medical facts.
Practice Implications
This decision significantly impacts suppression motions involving blood testing. Practitioners should focus challenges on whether testing revealed legitimate private medical information rather than arguing warrant scope limitations for contraband detection. The ruling suggests broader testing authority for law enforcement once blood is lawfully obtained, provided tests target only contraband and don’t compromise legitimate privacy interests in medical information.
Case Details
Case Name
State v. Price
Citation
2012 UT 7
Court
Utah Supreme Court
Case Number
No. 20090990
Date Decided
January 27, 2012
Outcome
Affirmed
Holding
Individuals do not have a reasonable expectation of privacy in contraband contents of lawfully seized blood, and testing for contraband that cannot reveal legitimate privacy interests does not implicate Fourth Amendment protections.
Standard of Review
Correctness for the court’s ruling on a motion to suppress, including its application of law to facts; clearly erroneous for underlying factual findings
Practice Tip
When challenging the scope of search warrants for blood testing, focus on whether the testing revealed legitimate private medical information beyond contraband detection, as contraband itself receives no Fourth Amendment protection.
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