State v. Hoffman

515 P.3d 912, 321 Or. App. 330
CourtCourt of Appeals of Oregon
DecidedAugust 10, 2022
DocketA173684
StatusPublished
Cited by2 cases

This text of 515 P.3d 912 (State v. Hoffman) is published on Counsel Stack Legal Research, covering Court of Appeals of Oregon primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. Hoffman, 515 P.3d 912, 321 Or. App. 330 (Or. Ct. App. 2022).

Opinion

Argued and submitted February 28; conviction on Count 1 reversed and remanded, remanded for resentencing, otherwise affirmed August 10; petition for review denied December 15, 2022 (370 Or 602)

STATE OF OREGON, Plaintiff-Respondent, v. MICHAEL JOHN HOFFMAN, Defendant-Appellant. Washington County Circuit Court 19CR35185; A173684 515 P3d 912

Defendant appeals his conviction for driving under the influence of intoxi- cants (DUII). On appeal, he asserts three assignments of error. First, he assigns error to the trial court’s grant of the state’s motion for a postponement of the trial. Second, he assigns error to the denial of his motion to suppress evidence of his blood-alcohol test results (medical blood draw), arguing that the hospital staff’s disclosure of those results in compliance with ORS 676.260 infringed on his Fourth Amendment privacy interests. Third, he challenges the denial of his motion in limine to exclude the medical blood draw evidence, contending that the state did not establish an adequate chain of custody. Held: The trial court did not abuse its discretion in granting the state’s motion for a continuance. The trial court did, however, err in denying defendant’s motion in limine to exclude the medical blood draw based on defendant’s objection to the inadequate chain of custody, which was not harmless with respect to the DUII conviction. Finally, as explained in State v. Miller, 284 Or App 818, 395 P3d 584, vac’d, 362 Or 300, 408 P3d 1079 (2017), which controls in this case, defendant does not have a privacy interest in his blood-alcohol test results under the Fourth Amendment, and the trial court did not err in denying defendant’s motion to suppress on that basis. Conviction on Count 1 reversed and remanded; remanded for resentencing; otherwise affirmed.

Donald R. Letourneau, Senior Judge. Joel C. Duran, Deputy Public Defender, argued the cause for appellant. Also on the briefs was Ernest G. Lannet, Chief Defender, Criminal Appellate Section, Office of Public Defense Services. Joanna L. Jenkins, Assistant Attorney General, argued for respondent. Also on the brief were Ellen F. Rosenblum, Attorney General, and Benjamin Gutman, Solicitor General. Before Ortega, Presiding Judge, and Powers, Judge, and Hellman, Judge. Cite as 321 Or App 330 (2022) 331

HELLMAN, J. Conviction on Count 1 reversed and remanded; remanded for resentencing; otherwise affirmed. 332 State v. Hoffman

HELLMAN, J. Defendant appeals his conviction for driving under the influence of intoxicants (DUII). ORS 813.010(4). On appeal, he asserts three assignments of error. First, he assigns error to the trial court’s grant of the state’s motion for a postponement of the trial. Second, he assigns error to the denial of his motion to suppress evidence of his blood- alcohol test results (medical blood draw), arguing that the hospital staff’s disclosure of those results in compliance with ORS 676.260 infringed on his Fourth Amendment pri- vacy interests. Third, he challenges the denial of his motion in limine to exclude the medical blood draw evidence, con- tending that the state did not establish an adequate chain of custody. For the reasons below, we conclude that defendant’s first assignment of error is unpreserved in part and that the trial court did not otherwise abuse its discretion in grant- ing the state’s request for a postponement. As to defendant’s third assignment of error, we accept the state’s concession that it did not lay an adequate foundation for the admission of the medical records containing defendant’s blood-alcohol level. Because the issue raised in defendant’s second assign- ment of error regarding the Fourth Amendment is likely to arise on remand, we resolve that issue and conclude that defendant’s argument is foreclosed by our decision in State v. Fincher, 303 Or App 165, 166, 462 P3d 780 (2020), rev’d in part on other grounds, 368 Or 560, 494 P3d 927 (2021) (readopting State v. Miller, 284 Or App 818, 395 P3d 584, vac’d, 362 Or 300, 408 P3d 1079 (2017)), in which we reaf- firmed that individuals do not have an expectation of privacy under the Fourth Amendment in blood-alcohol test results under the limited circumstances described by ORS 676.260. We therefore reverse and remand for further proceedings. BACKGROUND FACTS The relevant facts are largely undisputed. Defen- dant was riding his motorcycle when he was involved in a car crash. He was taken to the hospital for treatment, where hospital staff performed a blood test in the course of provid- ing medical care (medical blood draw). When Officer Welter arrived at the hospital about an hour and a half later to Cite as 321 Or App 330 (2022) 333

speak with defendant, a nurse informed her that the med- ical blood draw results showed that defendant had a blood alcohol content (BAC) of 0.257 percent. Officer Welter then spoke to defendant in his hospital room, where he consented to a second blood draw (implied-consent blood draw). Defendant was charged with DUII (Count 1) and driving while suspended (Count 2), ORS 811.182(4).1 Defen- dant filed a motion to suppress evidence of the implied- consent blood draw on August 20, 2019, which was 21 days before his scheduled September 10, 2019, trial date. At a pretrial hearing on the morning of September 10, the trial court granted defendant’s motion to suppress the implied- consent blood draw, concluding that it was obtained in viola- tion of defendant’s right to counsel. The state then requested that the trial scheduled for later that day be postponed so that it could subpoena the medical blood draw. The state explained that, while it should have subpoenaed the medical blood draw earlier, it had instead planned to rely on the implied-consent blood draw up until defendant filed his motion to suppress 21 days before trial. At that point, accounting for defendant’s likely objections, the state did not believe it could successfully sub- poena the medical blood draw in time for the existing trial date and did not attempt to do so. The state conceded that it “should have requested those” earlier but asked for a setover based on the trial court’s suppression of the implied-consent blood draw. When the trial court asked whether postponing the trial would prejudice him, defendant responded that he did not believe the state’s explanation was “sufficient good cause” for a postponement and that the state should have subpoenaed the medical blood draw earlier. Defendant did not argue that the court should dismiss the indictment on that basis. Instead, he argued that he would be prejudiced by any delay because he wanted to proceed to trial that day and file a motion for judgment of acquittal. He expected that the trial court would grant the motion, given the lack of a

1 Defendant does not challenge his conviction for driving while suspended, ORS 811.182(4), on appeal. 334 State v. Hoffman

BAC in the record. Defendant also argued that if the trial were postponed, he would need to spend time and resources hiring an expert and litigating the state’s subpoena. After hearing from both parties, the trial court granted the state’s motion to reset the trial date.

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Cite This Page — Counsel Stack

Bluebook (online)
515 P.3d 912, 321 Or. App. 330, Counsel Stack Legal Research, https://law.counselstack.com/opinion/state-v-hoffman-orctapp-2022.