People v. चोट्टसot, 63 N.Y.2d 945 (1984)
A blood test administered to a suspect is admissible as evidence in a driving while intoxicated case if administered within two hours of the suspect’s formal arrest, and the determination of when the arrest occurred is a factual finding that, if affirmed by the lower courts, will not be disturbed by the Court of Appeals.
Summary
The New York Court of Appeals upheld a County Court order affirming a Town Court’s denial of a motion to suppress blood test results in a driving while intoxicated case. The defendant argued the blood test, indicating a .17% blood-alcohol level, was taken in violation of Vehicle and Traffic Law § 1194(1)(1), which requires the test to be administered within two hours of arrest. The Court of Appeals deferred to the affirmed finding that the defendant’s arrest occurred at 8:35 p.m., making the subsequent blood test admissible, as it was administered within the statutory time limit. This case emphasizes the importance of establishing the precise time of arrest when determining the admissibility of blood alcohol tests.
Facts
On August 15, 1981, the defendant was involved in a car accident at approximately 7:00 p.m., crashing into a bridge abutment. Police arrived and found the defendant injured and trapped in the vehicle. He was extricated around 7:45 p.m. and, while disoriented, resisted medical assistance, requiring restraint. At 8:35 p.m., a police officer interviewed the defendant at the hospital, observed signs of intoxication (bloodshot eyes, slurred speech), and formally arrested him, reading his Miranda rights. A blood test was administered shortly before 10:00 p.m., revealing a blood-alcohol level of .17%.
Procedural History
The defendant moved to suppress the blood test results in Town Court, arguing the test was taken more than two hours after his purported arrest at the accident scene. The Town Court denied the motion. The defendant pleaded guilty to driving while intoxicated but appealed the Town Court’s order. The County Court affirmed the Town Court’s decision. The defendant then appealed to the New York Court of Appeals.
Issue(s)
Whether the blood test results should have been suppressed because the test was administered more than two hours after the defendant’s arrest, in violation of Vehicle and Traffic Law § 1194(1)(1)?
Holding
No, because the affirmed finding of the Town Court established that the defendant was not arrested until 8:35 p.m., making the blood test, administered before 10:00 p.m., compliant with the statutory time limit.
Court’s Reasoning
The Court of Appeals emphasized that the defendant’s argument hinged on a factual assertion: that he was effectively arrested at the scene of the accident, more than two hours before the blood test. However, the Town Court made a factual finding, affirmed by the County Court, that the defendant was not formally arrested until 8:35 p.m. The Court of Appeals stated, “in view of the affirmed finding of the Town Court that defendant was not arrested until 8:35 p.m., the determination that the test was administered within the statutory time limit may not be disturbed by this court (cf. Humphrey v State of New York, 60 NY2d 742, 743-744).” Because the lower courts agreed on the timing of the arrest, the Court of Appeals deferred to this finding, thus validating the admissibility of the blood test. The court did not delve into a deeper analysis of what constitutes an arrest, because the lower court’s finding of fact was determinative. The critical point for legal professionals is the importance of establishing a clear and supportable timeline of events to determine when an arrest occurred for the purposes of applying Vehicle and Traffic Law § 1194(1)(1).