Joshua Parks v. State of Arkansas

2020 Ark. App. 267, 599 S.W.3d 382
CourtCourt of Appeals of Arkansas
DecidedApril 29, 2020
StatusPublished
Cited by3 cases

This text of 2020 Ark. App. 267 (Joshua Parks v. State of Arkansas) is published on Counsel Stack Legal Research, covering Court of Appeals of Arkansas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
Joshua Parks v. State of Arkansas, 2020 Ark. App. 267, 599 S.W.3d 382 (Ark. Ct. App. 2020).

Opinion

Cite as 2020 Ark. App. 267 Reason: I attest to the accuracy and integrity of this document ARKANSAS COURT OF APPEALS Date: 2021-06-16 10:06:15 DIVISION II Foxit PhantomPDF Version: 9.7.5 No. CR-19-649

Opinion Delivered: April 29, 2020 JOSHUA PARKS APPELLANT APPEAL FROM THE FAULKNER V. COUNTY CIRCUIT COURT [NO. 23CR-15-467] STATE OF ARKANSAS APPELLEE HONORABLE CHARLES E. CLAWSON, JR., JUDGE

AFFIRMED

RITA W. GRUBER, Chief Judge

A Faulkner County Circuit Court jury found appellant Joshua Parks guilty of

negligent homicide, reckless driving, and first-degree battery for which he was sentenced to

concurrent sentences of twelve months in the county jail, three months in the county jail,

and sixty-six months in the Arkansas Department of Correction plus fines and fees totaling

$5,400. His sole point on appeal is that the trial court erred in denying his motion to suppress

a blood alcohol concentration (BAC) test. We affirm his convictions.

This case arose from a two-car crash on Interstate 40 near Mayflower. Shortly before

midnight on June 27, 2014, appellant rear-ended a minivan while traveling 100 miles per

hour, causing both vehicles to leave the roadway and overturn. The driver of the minivan

was traveling with his wife and three children, several of whom were ejected from the van,

resulting in multiple, serious injuries and the death of a five-year-old child. Matthew Toon, an Arkansas State Police Trooper, arrived on the scene at 12:11 a.m.

on June 28. At the hearing on appellant’s motion to suppress, Toon testified that he was

obligated by law to draw blood from the drivers of both vehicles because the accident

involved a fatality. He obtained a blood-draw kit from his patrol car and asked the paramedic

to draw appellant’s blood. Toon admitted that he did not obtain appellant’s consent. Toon

testified that he attempted to get appellant to respond to questions such as: What happened?

Can you hear me? Can you open your eyes? and Are you hurting? But appellant was

nonresponsive. Toon believed appellant was unconscious.

Mark Reeves, the paramedic, testified that appellant was “sleepy” and could not stay

awake. He confirmed Toon’s testimony that appellant did not respond to any of their

questions. The standard blood-consent form used by Reeves indicates that appellant did not

consent to the blood draw and that it was performed at Toon’s request under appellant’s

“implied consent” because he was “unresponsive due to possible” ethanol or alcohol

consumption. Reeves drew appellant’s blood, which subsequent testing revealed contained

a BAC of .066%.

Before trial, appellant moved to suppress the results of the BAC test on the ground

that warrantless blood draws violate the Fourth and Fourteenth Amendments of the United

States Constitution, citing the recently issued United States Supreme Court decision in

Birchfield v. North Dakota, 136 S. Ct. 2160 (2016) (holding that a breath test, but not a blood

test, may be administered as a warrantless search incident to a lawful arrest for drunk driving).

He also argued that the statutes authorizing the warrantless blood draw—Ark. Code Ann. §

2 5-65-202 and Ark. Code Ann. § 5-65-208—are unconstitutional.1 The State contended

that a warrantless search of appellant’s blood was required by the statute in effect at the time

of the accident, Ark. Code Ann. § 5-65-208, due to the resulting fatality.2 Citing Illinois v.

Krull, 480 U.S. 340 (1987), the State argued that Officer Toon’s reliance on this statute was

objectively reasonable because the incident occurred two years before Birchfield was decided.

The trial court agreed and denied appellant’s motion to suppress, basing its decision on

Illinois v. Krull and Officer Toon’s good faith and reasonable reliance on the law at the time

of the accident.

Appellant’s sole point on appeal is that the trial court erred in denying his motion to

suppress the evidence. We review the denial of a motion to suppress de novo considering

the totality of the circumstances, reviewing findings of historical fact for clear error and

determining whether those facts give rise to reasonable suspicion or probable cause, giving

due weight to inferences drawn by the trial court and proper deference to the trial court’s

findings. Yarbrough v. State, 370 Ark. 31, 257 S.W.3d 50 (2007). We defer to the superior

position of the trial court to evaluate the credibility of witnesses at a suppression hearing,

and any conflicts in the testimony of witnesses are for the trial court to resolve. Rainey v.

1 Both statutes were amended in 2017 to require a warrant to test a person’s blood based on probable cause that the person was operating a motor vehicle while intoxicated. See also Dortch v. State, 2018 Ark. 135, 544 S.W.3d 518 (holding that a previous version of Ark. Code Ann. § 5-65-202 was unconstitutional as applied to Dortch). 2 Subsection (a) of the 2014 version of the statute provided that when a driver was involved in an accident “resulting in loss of human life or when there is reason to believe death may result, a chemical test of the driver’s blood, breath, saliva, or urine shall be administered to the driver . . . to determine the presence of and percentage of alcohol concentration or the presence of a controlled substance, or both, in the driver’s body.”Ark. Code Ann. § 5-65-208(a) (Supp. 2013).

3 State, 2017 Ark. App. 427, at 7, 528 S.W.3d 288, 293. We reverse only if the trial court’s

ruling is clearly against the preponderance of the evidence. Menne v. State, 2012 Ark. 37,

386 S.W.3d 451.

The Fourth Amendment provides that “[t]he right of the people to be secure in their

persons, houses, papers, and effects, against unreasonable searches and seizures, shall not be

violated, and no Warrants shall issue, but upon probable cause[.]” U.S. Const. amend. IV.

A BAC test is a search and thus normally requires a warrant. Mitchell v. Wisconsin, 139 S. Ct.

2525, 2533 (2019). A warrantless search of a person is reasonable only if it falls within a

recognized exception to the warrant requirement. Dortch, 2018 Ark. 135, 544 S.W.3d 518

(citing Missouri v. McNeely, 569 U.S. 141 (2013)).

One of these recognized exceptions is “search incident to arrest” in a drunk-driving

arrest. In Birchfield, the United States Supreme Court held that a drunk-driving arrest,

without more, justifies a warrantless breath test but not a warrantless blood test. Birchfield,

136 S. Ct. at 2184–85. The Birchfield Court also addressed another exception to the warrant

requirement—consent. It is well established that a search is reasonable when the subject

consents, and sometimes the consent need not be express but may be inferred from context.

Id. at 2185. The searches in Birchfield were conducted pursuant to statutorily imposed

implied-consent laws similar to the version of Arkansas Code Annotated section 5-65-202

that existed at the time of the incident here.3

3 (a) Any person who operates a motor vehicle or is in actual physical control of a motor vehicle in this state is deemed to have given consent, subject to the provisions of § 5-65-203, to one (1) or more chemical tests of his or her blood, breath, saliva, or urine for the purpose of determining the alcohol or controlled substance content of his or her breath or blood if:

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2020 Ark. App. 267, 599 S.W.3d 382, Counsel Stack Legal Research, https://law.counselstack.com/opinion/joshua-parks-v-state-of-arkansas-arkctapp-2020.