State of Minnesota v. Heath Allen Atwood

Summary

The court held that a physical blood sample drawn during emergency medical treatment is not “information” protected by Minnesota’s statutory physician-patient privilege. Applying the ordinary meaning of the statutory term, the court concluded that the privilege did not bar seizure of the sample or admission of the law-enforcement blood-alcohol test derived from it, and it affirmed the court of appeals. The dissent argued that prior precedent required treating the sample as privileged and would have reinstated the suppression order.