Vivian Faith Snyder v. State

CourtCourt of Appeals of Georgia
DecidedFebruary 20, 2025
DocketA24A1554
StatusPublished

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

Bluebook
Vivian Faith Snyder v. State, (Ga. Ct. App. 2025).

Opinion

FOURTH DIVISION DILLARD, P. J., BROWN and PADGETT, JJ.

NOTICE: Motions for reconsideration must be physically received in our clerk’s office within ten days of the date of decision to be deemed timely filed. https://www.gaappeals.us/rules

February 20, 2025

In the Court of Appeals of Georgia A24A1554. SNYDER v. THE STATE.

PADGETT, Judge.

In this appeal following the grant of an interlocutory application, Vivian Faith

Snyder challenges the trial court’s denial of her motion to suppress. Specifically,

Snyder contends that the results of a blood draw for a state-administered chemical test

should be suppressed because the blood draw was performed by the arresting officer,

in violation of OCGA § 40-6-392. For the reasons that follow, we affirm.

When considering the denial of a motion to suppress, we view the evidence “in

favor of the court’s ruling, and we review de novo the trial court’s application of the

law to undisputed facts.” Creamer v. State, 337 Ga. App. 394, 395 (788 SE2d 69)

(2016) (citation and punctuation omitted). I. Facts and procedural history

So viewed, the record shows that in December 2022, a Georgia State Trooper

saw Snyder speeding in her vehicle and initiated a traffic stop. After an initial

investigation, the trooper began investigating Snyder for DUI. The trooper performed

a field sobriety test and a portable breath test. The trooper then arrested Snyder for

DUI. Snyder allegedly consented to a State-administered test of her blood. The

trooper, who is a certified phlebotomist, performed the blood draw for the blood test.

Snyder was subsequently charged with DUI (less safe) (alcohol), DUI (per se), and

speeding.

Snyder filed a motion to suppress and motion in limine, seeking to suppress the

results of the chemical test of her blood. Snyder argued that under OCGA § 40-6-392

(a) (2) the trooper, as the arresting officer, was not permitted to conduct the blood

draw. The trial court denied the motion after a hearing. The court certified its ruling

for immediate review, and we granted Snyder’s application for interlocutory appeal.

This appeal follows.

II. Whether OCGA § 40-6-392 (a) (2) prohibited the trooper from conducting the

blood draw

2 Snyder first complains that under the statute, the trooper could not conduct the

blood draw. OCGA § 40-6-392 (a) (2) states:

When a person shall undergo a chemical test at the request of a law enforcement officer, only a physician, registered nurse, laboratory technician, emergency medical technician, or other qualified person may withdraw blood for the purpose of determining the alcoholic content therein, provided that this limitation shall not apply to the taking of breath or urine specimens. No physician, registered nurse, or other qualified person or employer thereof shall incur any civil or criminal liability as a result of the medically proper obtaining of such blood specimens when requested in writing by a law enforcement officer[.]

Snyder contends that the trooper could not conduct the blood draw because an

arresting officer is not explicitly enumerated and the phrase “other qualified person”

does not apply to the arresting officer. However, the plain language of OCGA § 40-6-

392 (a) (2) reveals nothing suggesting that an arresting officer is prohibited from

serving as an “other qualified person” to withdraw blood. See Deal v. Coleman, 294

Ga. 170, 173 (1) (a) (751 SE2d 337) (2013) (“[I]f the statutory text is ‘clear and

unambiguous,’ we attribute to the statute its plain meaning, and our search for

3 statutory meaning is at an end.”).1 In other words, the legislature has plainly stated

that in addition to a physician, registered nurse, laboratory technician, and an

emergency medical technician, an “other qualified person” may conduct the blood

draw. Snyder acknowledges that the trooper was a certified phlebotomist.

Additionally, the program that the trooper completed to become a certified

phlebotomist was approved of by the Georgia Department of Public Safety, whose

policy states that

[t]his policy establishes the protocol for obtaining a blood draw from a subject by Department of Public Safety (DPS) members who have been trained as law enforcement phlebotomists or who have been trained in blood draws and meet the statutory definition of a qualified person as set out in OCGA 40-6-392(a) (2).

11.08.1 DPS. Snyder’s argument is that we must view the trooper only in his role as

an officer and that he is incapable of holding multiple roles simultaneously. That is

incorrect and unsupported by the statute. Snyder’s argument fails to recognize that

1 Snyder also asks us to ignore a case relied on by the trial court, State v. Guerra, 169 Idaho 486 (497 P3d 1106) (2021). In Guerra, the Supreme Court of Idaho interpreted a similar statute as permitting an officer, also a phlebotomist, to conduct a blood draw. The trial court was permitted to consider Guerra as persuasive authority. See Hill v. Burnett, 349 Ga. App. 260, 262 (1) (a) (825 SE2d 617) (2019). 4 the trooper can act as both a law enforcement officer and also a phlebotomist under

these circumstances. Accordingly, the trooper was permitted to conduct the blood

draw under the statute and under DPS policy.2

III. Whether the trooper’s conducting the blood draw is otherwise impermissible

Relying on the Supreme Court of the United States’ opinion in Schmerber v.

California, 384 U. S. 757 (86 SCt 1826, 16 LE2d 908) (1966), Snyder also suggests that

the trooper’s performance of the blood draw may constitute an unreasonable search

and seizure. In particular, Snyder points to the following two paragraphs in Schmerber:

Finally, the record shows that the test was performed in a reasonable manner. Petitioner’s blood was taken by a physician in a hospital environment according to accepted medical practices. We are thus not presented with the serious questions which would arise if a search involving use of a medical technique, even of the most rudimentary sort,

2 In her brief, Snyder contends that under this interpretation of the statute, an arresting officer’s duties as a law enforcement officer may be at odds with his or her duties as a medical professional. However, the policy concerns raised by Snyder on appeal are solely the province of the General Assembly, not this Court. See Patrick v. Kingston, 370 Ga. App. 570, 578 (1) n.22 (898 SE2d 560) (2024); Kenerly v. State, 311 Ga. App. 190, 195 (1) (715 SE2d 688) (2011) (“This court is charged with the duty of interpreting statutes, not enacting them. It is a fundamental principle that the legislature, and not the courts, is empowered by the Constitution to decide public policy, and to implement that policy by enacting laws; and the courts are bound to follow such laws if constitutional.”) (citation and punctuation omitted).

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Related

Schmerber v. California
384 U.S. 757 (Supreme Court, 1966)
Saxton v. Coastal Dialysis & Medical Clinic, Inc.
476 S.E.2d 587 (Supreme Court of Georgia, 1996)
McGILL v. THE STATE OF GEORGIA, by Davis, Solicitor-General
71 S.E.2d 548 (Supreme Court of Georgia, 1952)
Atlanta Independent School System v. Lane
469 S.E.2d 22 (Supreme Court of Georgia, 1996)
Bradway v. American National Red Cross
426 S.E.2d 849 (Supreme Court of Georgia, 1993)
Haynes v. Wells
538 S.E.2d 430 (Supreme Court of Georgia, 2000)
GHG, INC. v. Bryan
566 S.E.2d 662 (Supreme Court of Georgia, 2002)
KENERLY v. State
715 S.E.2d 688 (Court of Appeals of Georgia, 2011)
Creamer v. the State
788 S.E.2d 69 (Court of Appeals of Georgia, 2016)
Deal v. Coleman
751 S.E.2d 337 (Supreme Court of Georgia, 2013)
Alexander v. State
870 S.E.2d 729 (Supreme Court of Georgia, 2022)

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Vivian Faith Snyder v. State, Counsel Stack Legal Research, https://law.counselstack.com/opinion/vivian-faith-snyder-v-state-gactapp-2025.