State v. Hoerle

The Supreme Court affirmed the district court’s denial of Defendant’s motion for a new trial, holding that the good faith exception to the exclusionary rule applied in this case.Defendant was convicted of driving under the influence (DUI). The following day, the United States Supreme Court held in Birchfield v. North Dakota, __ U.S. ___ (2016), that a blood test may not be administered without a warrant as a search incident to an arrest for DUI. Defendant timely moved for a new trial, arguing that, in light of the new rule of constitutional law announced in Birchfield, it was error to admit the result of a warrantless test of his blood. The district court overruled the motion. The Supreme Court affirmed, holding that the good faith exception applies to warrantless blood draws connected prior to the United States Supreme Court’s decision in Birchfield. View "State v. Hoerle" on Justia Law