State v. John Phillip Couch, II

CourtCourt of Appeals of Texas
DecidedAugust 29, 2019
Docket03-16-00727-CR
StatusPublished

This text of State v. John Phillip Couch, II (State v. John Phillip Couch, II) is published on Counsel Stack Legal Research, covering Court of Appeals of Texas primary law. Counsel Stack provides free access to over 12 million legal documents including statutes, case law, regulations, and constitutions.

Bluebook
State v. John Phillip Couch, II, (Tex. Ct. App. 2019).

Opinion

TEXAS COURT OF APPEALS, THIRD DISTRICT, AT AUSTIN

ON REMAND

NO. 03-16-00727-CR

The State of Texas, Appellant

v.

John Phillip Couch, II, Appellee

FROM THE 207TH DISTRICT COURT OF COMAL COUNTY NO. CR2013-444, THE HONORABLE R. BRUCE BOYER, JUDGE PRESIDING

OPINION

This cause is before us on remand from the Texas Court of Criminal Appeals. On

original submission, this Court considered whether the District Court abused its discretion in

granting the motion to suppress of appellee John Phillip Couch, II, who argued that the State had

violated his Fourth Amendment rights by drawing his blood without a search warrant. This

Court concluded that the warrantless blood draw was justified by exigent circumstances and

reversed the District Court’s order for that reason. See State v. Couch, No. 03-16-00727-CR,

2018 Tex. App. LEXIS 8855, at *17–19 (Tex. App.—Austin Oct. 31, 2018) (mem. op., not

designated for publication). After this Court issued its opinion and judgment, the Court of

Criminal Appeals issued an opinion that addressed the deference a reviewing court owes to a trial court’s findings of fact and conclusions of law in cases involving claims of exigent

circumstances. See State v. Garcia, 569 S.W.3d 142, 148–52 (Tex. Crim. App. 2018). Because

this Court did not have the benefit of Garcia when it issued its previous opinion, the Court of

Criminal Appeals remanded this cause to us for reconsideration. For the following reasons, we

affirm the District Court’s order granting Couch’s motion to suppress.

BACKGROUND 1

At approximately 7:53 p.m. on February 25, 2012, Texas Department of Public

Safety Trooper David Kral was notified of a vehicle collision in Comal County, on FM 306 near

Canyon Park Road. Kral arrived at the scene approximately 30 minutes later, at 8:24 p.m. Upon

arrival, Kral saw that a Corvette and a Chevy pickup truck had collided in the roadway and were

blocking traffic. Emergency personnel and law-enforcement officers were already at the scene.

Kral spoke with a sheriff’s deputy who informed him that eyewitnesses had observed the driver

of the Corvette, later identified as Couch, “driving recklessly within the parking lot” of a

convenience store and “attempting to get onto [FM] 306.” The deputy added that as the Corvette

was exiting the parking lot, it “went into the wrong lane and went head on with another vehicle.”

There were two individuals in the Chevy pickup at the time of the collision, one of whom was

hospitalized with a broken thumb.

As the lead investigator at the scene, Kral was responsible for “[g]athering all the

facts as far as where the vehicles were on the roadway,” “getting . . . certain documents from the

crash,” “identifying the other occupants of the crash,” “getting witness statements,” and speaking

1 The following recitation of facts is based on the evidence admitted at the suppression hearing, including the testimony of the arresting officer, a copy of his offense report, and a copy of a video recording taken from the officer’s patrol-car dash camera. 2 with “the other deputies that were there on scene.” Kral was also responsible for completing a

written report of the collision. The role of the other officers was to “assist[] with the overall

crash scene” by “getting witness statements,” “identifying drivers,” “getting facts,” and

“securing the scene, making sure that—that nobody else crashes into these cars while they’re just

sitting in the middle of the road.”

While the other officers were completing those tasks, Kral spoke with Couch. He

noticed that Couch “had an abrasion across [the] left part of his head, and he was also

complaining of his chest.” As a precautionary measure, Kral “brought him over to Canyon Lake

EMS personnel,” who informed Kral that they had already “checked [Couch] over” and released

him because he “had refused any further treatment.”

Kral then brought Couch to his patrol car and asked him questions concerning the

collision. During the interview, Kral smelled alcohol on Couch’s breath. Kral suspected that

Couch was intoxicated and proceeded to administer field sobriety tests. Kral estimated that he

began conducting the tests approximately 30 minutes after his arrival at the scene and that the

tests took approximately 20 to 30 minutes to complete. After conducting the field sobriety tests,

Kral asked Couch “if he had anything else in his system or if there’s anything else in the car.”

Couch admitted that there “might” be marijuana in his vehicle, although he denied smoking any

marijuana that day. Couch then took a pill bottle out of his pocket that contained marijuana.

Based on the information that he had gathered during his investigation, Kral

arrested Couch for driving while intoxicated and possession of marijuana. Before leaving the

scene of the collision, Kral spoke with the other officers to inform them of Couch’s arrest, to

“check the status” of the occupants in the other vehicle, and to ensure that the clean-up of the

3 collision was under control. Kral then transported Couch to a hospital in downtown New

Braunfels, a drive that took approximately 45 minutes.

Upon arrival at the hospital, Kral began drafting a search warrant to draw Couch’s

blood, a process that took approximately 30 minutes to complete. After attempting

unsuccessfully to contact a judge who could sign the warrant, Kral decided to forgo the search-

warrant process and obtain a sample of Couch’s blood without a warrant under the authority of

the mandatory-blood-draw statute. 2 Kral explained, “I had every intention [of] getting the

warrant. But at some point, like I said, that little light went off in the back of my mind saying

there’s no reason for me to have to delay this.” When asked if he believed that he “would have

had time to get a search warrant and adequately get an accurate and reliable blood analysis done

on the defendant,” Kral answered, “No.” Kral obtained a sample of Couch’s blood without a

warrant at approximately 10:50 p.m., approximately three hours after he had been dispatched to

the collision.

The District Court granted Couch’s motion to suppress and later made findings of

fact and conclusions of law, including that “the overall circumstances of the incident do not

2 See Tex. Transp. Code § 724.012(b) (permitting warrantless blood draw if, among other reasons, “an individual other than the [suspect] has suffered bodily injury and been transported to a hospital or other medical facility for medical treatment”). In this case, one of the occupants of the other vehicle had been injured and transported to a hospital for medical treatment. Thus, at the time of Couch’s arrest in 2012, the statute permitted Couch’s blood to be drawn without a warrant.

However, in 2014, the Texas Court of Criminal Appeals held that “a nonconsensual search of a DWI suspect’s blood conducted pursuant to the . . . Transportation Code, when undertaken in the absence of a warrant or any applicable exception to the warrant requirement, violates the Fourth Amendment.” State v. Villarreal, 475 S.W.3d 784, 815 (Tex. Crim. App. 2014). 4 demonstrate exigent circumstances so compelling that a warrantless, non-consensual blood draw

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