Miller v. Idaho State Patrol

A State trooper arrested Respondent Jason Miller for DUI. The trooper observed that Respondentâs pupils were dilated and asked that Respondent perform some field sobriety tests, which Respondent ultimately failed. The trooper discovered scissors in Respondentâs pocket that were used for cleaning a marijuana pipe. Respondent admitted to smoking marijuana âevery day.â The trooper took respondent to a hospital for a urine test, but at the hospital, Respondent refused to willingly provide a sample. A registered nurse at the hospital then catheterized Respondent at the trooperâs request, and extracted the sample. Respondent later pled guilty to possession of drugs, drug paraphernalia and to DUI. Respondent appealed the trial courtâs grant of summary judgment to the State. He argued that his civil rights under 42 U.S.C 1983 and state tort laws were violated when he was âunreasonablyâ catheterized. The Supreme Court found that because âAmerican search-and-seizure law is undeveloped as to when an officer may administer an involuntary warrantless catheterization on a suspect,â the state trooper was entitled to qualified immunity for both of Respondentâs the federal and state law claims.