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 the Fourth Amendment requires voluntary consent before an officer may conduct a warrantless blood draw from a DUI arrestee, including a juvenile. Considering the totality of the circumstances, the court upheld the juvenile court’s finding that Tyler’s consent was involuntary and ordered suppression of the blood-draw evidence. The court declined to decide Tyler’s legal-capacity, state constitutional, and Parents’ Bill of Rights arguments. The concurring justice agreed with the result under abuse-of-discretion review but would have considered de novo review and expressed concern that the ruling gives law enforcement insufficient guidance.