AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

• An officer arrested the Defendant for driving while intoxicated after observing the Defendant's performance on several field sobriety tests. The Defendant consented to a blood test, which was conducted at San Juan Regional Medical Center by Nicole McNealy, an Emergency Department Technician. The Defendant was subsequently charged with driving under the influence and child abuse. The Defendant challenged the admissibility of the blood test results, arguing that McNealy was not authorized to draw blood under the relevant statute (para 2-3).

Procedural History

• District Court of San Juan County: The court granted the Defendant's motion to suppress the blood test results, ruling that the technician who drew the blood was not authorized under the Implied Consent Act (para 1).

Parties' Submissions

• Plaintiff-Appellant (State): Argued that McNealy’s training and experience working at the Medical Center qualified her as a laboratory technician or technologist employed by a hospital or physician for purposes of the statute authorizing blood draws in DUI cases (para 3).
• Defendant-Appellee: Contended that McNealy, being licensed as an emergency medical technician (EMT), did not fall within the categories of individuals authorized to draw blood under the statute, relying on precedent that excluded EMTs from the list of authorized blood drawers (para 3).

Legal Issues

• Whether the district court erred in excluding blood test results on the basis that the technician who drew the blood was not authorized under the Implied Consent Act (para 1).

Disposition

• The Court of Appeals reversed the district court’s order excluding the blood test results and remanded for further proceedings (para 11).

Reasons

• The panel, consisting of Judges Linda M. Vanzi, J. Miles Hanisee, and Jacqueline R. Medina, unanimously found that the district court abused its discretion by excluding the blood test results based on a misinterpretation of the law. The Court of Appeals relied on a recent decision, State v. Adams, which clarified that emergency medical technicians (EMTs) could be authorized to draw blood under certain conditions, contrary to the district court's reliance on State v. Garcia. The appellate court determined that the case was distinguishable from Garcia on both legal and factual grounds, notably because the State argued that McNealy qualified as a laboratory technician due to her skills and experience, not merely her EMT license. The court emphasized that McNealy's employment at the Medical Center, her training, and her experience in performing legal blood draws met the criteria for a "laboratory technician" under the Implied Consent Act. Therefore, the appellate court concluded that the district court's decision was based on a misunderstanding of the law and reversed the order to exclude the blood test results (paras 4-10).