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Facts

  • The Defendant was arrested for driving while intoxicated and had his blood drawn for testing by an Emergency Room Technician at the San Juan Regional Medical Center. The Defendant was charged with aggravated driving while intoxicated and driving with a suspended license. He moved to exclude the blood test results, arguing that the technician was not authorized to draw blood under the relevant statute because he did not fall within the specified categories of individuals authorized to perform such tests (paras 2-3).

Procedural History

  • District Court of San Juan County: The court granted the Defendant's motion to suppress the blood test results on the grounds that the technician was not authorized under the Implied Consent Act to draw the Defendant's blood (para 3).

Parties' Submissions

  • Plaintiff-Appellant (State): Argued that the technician’s training and experience qualified him to draw blood for purposes of the statute in question (para 2).
  • Defendant-Appellee: Argued that the technician did not fall into any of the categories of individuals authorized to draw blood under the statute, relying on a previous case to support the motion to exclude the blood test results (para 2).

Legal Issues

  • Whether the Emergency Room Technician was authorized under the Implied Consent Act to draw the Defendant's blood for testing purposes (para 1).

Disposition

  • The Court of Appeals reversed the district court’s order excluding the Defendant’s blood test results and remanded for further proceedings (para 10).

Reasons

  • The Court of Appeals, with Judges Linda M. Vanzi, J. Miles Hanisee, and Jacqueline R. Medina concurring, found that the district court abused its discretion by excluding the blood test results based on a misapprehension of the law. The Court distinguished this case from the precedent cited by the Defendant, noting that the technician's employment at the Medical Center and his training and experience qualified him as a "laboratory technician" under the statute. The Court concluded that the district court's decision was based on a misunderstanding of the law, specifically the qualifications required under the Implied Consent Act for individuals performing blood-alcohol tests. The Court emphasized that formal training by the Scientific Laboratory Division was not a prerequisite for authorization to draw blood under the Act, and that the technician's qualifications met the statutory requirements due to his training and experience in addition to his certification as an Emergency Medical Technician-Basic (paras 4-9).
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