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 Aztec police officer arrested the Defendant for driving while intoxicated (DWI) after observing multiple traffic law violations and an attempt to flee. The Defendant exhibited signs of intoxication and refused to perform a field sobriety test or submit to a chemical test. Subsequently, a warrant was obtained, and the Defendant's blood was drawn by Nicole McNealy, a hospital employee, at the San Juan County Regional Medical Center (para 2).

Procedural History

• District Court of San Juan County: The blood test results were excluded on the basis that Nicole McNealy was not authorized under the Implied Consent Act to draw the Defendant's blood (para 1).

Parties' Submissions

• Plaintiff-Appellant (State): Argued that McNealy’s training and experience qualified her as a laboratory technician or technologist employed by a hospital or physician for purposes of the Implied Consent Act (para 3).
• Defendant-Appellee: Contended that McNealy, being licensed as an emergency medical technician (EMT), did not fall into the categories of individuals authorized to draw blood under the relevant statute (para 3).

Legal Issues

• Whether the district court erred in excluding the blood test results on the basis that the individual who drew the Defendant's blood was not authorized under the Implied Consent Act (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 14).

Reasons

• Per Linda M. Vanzi, J. (J. Miles Hanisee, J., and Jacqueline R. Medina, J., concurring): The Court of Appeals found that the district court abused its discretion by excluding the blood test results based on a misinterpretation of the law. The court determined that the State has a right to appeal the exclusion of evidence if it is substantial proof of a material fact in the proceeding, rejecting the Defendant's argument that the State could not appeal because it had other evidence to convict (paras 5-7). The court concluded that the Implied Consent Act does not categorically exclude EMTs from drawing blood for law enforcement purposes and that an individual's qualifications under the Act should be determined based on their skills, training, and experience, not merely their job title or licensure. McNealy's training in phlebotomy and legal blood draws, her employment duties, and her experience performing legal blood draws for the Medical Center qualified her as a "laboratory technician" under the Act. Therefore, the exclusion of the blood test results was based on a misunderstanding of the law, constituting an abuse of discretion by the district court (paras 8-13).