People v. Casadei, 66 N.Y.2d 846 (1985)
A search warrant may be validly issued to obtain a blood sample in the event of a violation of the Penal Law, even when Vehicle and Traffic Law offenses are part of the same indictment; Vehicle and Traffic Law § 1194 does not constitute the exclusive method of obtaining a blood sample in such cases.
Summary
The New York Court of Appeals held that a blood sample obtained via a search warrant was admissible as evidence in a case involving both Penal Law (manslaughter, criminally negligent homicide) and Vehicle and Traffic Law violations (driving while intoxicated), despite the defendant’s argument that Vehicle and Traffic Law § 1194 provided the exclusive means for obtaining such samples. The court distinguished its prior ruling in People v. Moselle, emphasizing the presence of a court-ordered warrant based on probable cause in this case. The court also noted that the legislature subsequently amended Vehicle and Traffic Law § 1194 to overrule Moselle on its facts.
Facts
The defendant was involved in a two-car accident where the other driver died. Subsequently, the defendant was indicted on multiple charges, including manslaughter in the second degree, criminally negligent homicide, driving while intoxicated, and other Vehicle and Traffic Law violations. A chemical blood test was administered to the defendant without his consent, based on a search warrant.
Procedural History
The County Court granted the defendant’s motion to suppress the results of the blood test. The Appellate Division reversed the County Court’s order, denying the suppression motion. The defendant appealed to the New York Court of Appeals.
Issue(s)
Whether Vehicle and Traffic Law § 1194, in effect at the time of the accident, constituted the exclusive method of obtaining a blood sample for a violation of Vehicle and Traffic Law § 1192, precluding the use of a search warrant to obtain such evidence when Penal Law violations are also charged in the same indictment.
Holding
No, because a search warrant may validly be issued to obtain a blood sample in the event of a violation of the Penal Law, and, in such circumstances, the court declined to extend People v. Moselle to require separate resort to Vehicle and Traffic Law § 1194 to sustain Vehicle and Traffic Law offenses which are part of the same indictment.
Court’s Reasoning
The court distinguished this case from People v. Moselle, noting the critical difference: the presence of a court order based on probable cause authorizing the blood sample. The court acknowledged that Moselle held that Vehicle and Traffic Law § 1194 was the exclusive method for obtaining a blood sample for Vehicle and Traffic Law violations. However, the court emphasized that Matter of Abe A. established that a search warrant could be validly issued to obtain a blood sample in the event of a violation of the Penal Law.
The Court reasoned that requiring separate resort to Vehicle and Traffic Law § 1194 for the Vehicle and Traffic Law offenses, when those offenses are part of the same indictment as Penal Law violations, would be an unnecessary and impractical extension of Moselle. Furthermore, the court highlighted that the Legislature had amended Vehicle and Traffic Law § 1194 (L 1983, ch 481) to overrule Moselle on its facts, signaling a legislative intent to allow for blood samples to be obtained via warrant even in Vehicle and Traffic Law cases. The court stated: “It is clear that a search warrant may validly be issued to obtain a blood sample in the event of a violation of the Penal Law (Matter of Abe A., 56 NY2d 288), and, in such circumstances, we decline to extend Moselle to require separate resort to Vehicle and Traffic Law § 1194 to sustain Vehicle and Traffic Law offenses which are part of the same indictment.”
Therefore, the court concluded that the blood sample obtained via a valid search warrant was admissible, even though the defendant was also charged with Vehicle and Traffic Law violations.