Freddie Flonnory, Defendant Below-Appellant v. State of Delaware, Plaintiff Below-Appellee

Summary

The court held that a warrantless blood draw is not exempt from Fourth Amendment scrutiny merely because Delaware's implied-consent statute applies. When the State relies on consent, the trial court must determine voluntariness under the totality of the circumstances, including the defendant's knowledge, characteristics, cooperation, detention, questioning, and any coercion. The court remanded for that analysis and directed suppression, vacation of the conviction, and a new trial if consent was not voluntary. STRINE, Chief Justice, dissenting, would have affirmed because he viewed the implied-consent statute as a valid consent exception with adequate safeguards.