Tennessee Supreme Court Reverses Trial Court's Exclusion of Evidence In DUI Case

July 20, 2018

The Tennessee Supreme Court reversed a trial court’s decision to exclude certain evidence obtained from a blood sample drawn from the defendant, Angela Faye Daniel.  In this case, Daniel was arrested for driving under the influence, and she was transported to a medical facility for a blood draw.  Although the arresting officer obtained a search warrant for the blood draw, the officer failed to leave a copy of the warrant with Daniel, in violation of Tennessee Rule of Criminal Procedure 41.  The trial court suppressed the evidence obtained from the blood draw on this basis.  On interlocutory appeal by the State, the Court of Criminal Appeals affirmed the trial court’s suppression of the evidence.  The State appealed to the Tennessee Supreme Court.

The Supreme Court granted the appeal and requested additional briefing as to whether the Court should expand the good-faith exception adopted in State v. Davidson to include technical violations during the service of a search warrant when the search is otherwise constitutional and whether the Exclusionary Rule Reform Act (“the ERRA”) violates the Separation of Powers Clause of the Tennessee Constitution.

In its unanimous opinion authored by Chief Justice Jeff Bivins, the Court first noted that, in State v. Lowe, another case released today, the Court held that the ERRA violated the Separation of Powers Clause of the Tennessee Constitution.  The Court then went on to hold that a good-faith exception to the exclusionary rule applied in this case, given that any failure of the arresting officer to provide Daniel with a copy of the warrant was due to an inadvertent oversight and that the technical noncompliance did not prejudice her. 

As it also did in State v. Lowe, the Court provided guidance to trial courts as to what should be considered when hearing a motion to suppress based on technical violations of Tennessee Rule of Criminal Procedure 41.  Specifically, the Court directed that, in situations where a defendant has established that a search warrant, or its supporting affidavit, fails to comply with the technical requirements pursuant to Tennessee Rule of Criminal Procedure 41, the State then has the burden of establishing that the technical noncompliance was due to a good-faith error and that the error did not prejudice the defendant. 

Based on the Court’s determination in this case that a good-faith exception to the exclusionary rule was applicable, the Supreme Court reversed the judgment of the trial court and the Court of Criminal Appeals and remanded the matter to the trial court.

To read the Supreme Court’s unanimous opinion in State v. Angela Faye Daniel, authored by Chief Justice Jeff Bivins, go to the opinions section of TNCourts.gov.