State of Arizona, Appellee v. Don Jacob Havatone, Appellant

Summary

The court held that applying Arizona’s unconscious-clause statute to authorize a warrantless, nonconsensual blood draw from Havatone violated the Fourth Amendment because no case-specific exigent circumstances justified dispensing with a warrant. It further held that Arizona’s good-faith exception did not save the evidence because the draw resulted from a recurring department policy rather than an individualized determination that obtaining a warrant was impracticable. The court vacated the court of appeals’ decision, reversed the suppression ruling, and remanded for a determination of which state’s law governs and, if Nevada law applies, whether Nevada’s good-faith exception applies. The separate opinion would have upheld the good-faith exception based on the statute and then-existing Arizona law.