TBA Law Blog


Posted by: Katharine Heriges on Jul 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. 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, as so the state appealed to the Tennessee Supreme Court. In its unanimous opinion authored by Chief Justice Jeff Bivins, the court held 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.