The State of Arizona, Petitioner v. Hon. Jane A. Butler, Judge Pro Tempore of the Superior Court of the State Of…

Summary

The court held that a warrantless blood draw from a juvenile DUI arrestee requires voluntary consent under the Fourth Amendment, even when conducted under Arizona's implied-consent statute. Considering the totality of the circumstances, including the juvenile's age, emotional state, detention, absence of a parent, and the officer's admonition that testing was required, the court upheld the finding that Tyler's consent was involuntary and affirmed suppression of the blood-draw evidence. Justice Pelander concurred in the judgment but would have reviewed voluntariness de novo and would have found the consent voluntary under that standard.