Page 37 - North Carolina 2020 Legal Guide
P. 37
Task: Forced Blood and Breath Tests
Birchfield v. North Dakota, 136 S.Ct. 2160 (2015).
• Forced Blood Test under implied consent statute where refusal is
criminal under state law violates the Fourth Amendment and cannot
be saved as a search incident to arrest.
• Forced Breath Test under implied consent statute where refusal is
criminal under state law DOES NOT violate the Fourth Amendment
because it is valid as a search incident to arrest.
• THIS CASE HAS NO IMPACT IN STATES WHERE REFUSAL IS
CIVIL INFRACTION RATHER THAN CRIMINAL OFFENSE
©2020 Jack Ryan Legal & Liability Risk Management Institute 36