A Case Summary: People v. Blake Anthony-William Barton
On October 11, 2024, the Michigan Court of Appeals issued a decision in the case People of the State of Michigan v. Blake Anthony-William Barton.
The case involved a drunk driving investigation following a car accident in Britton, Michigan.
Background
The incident occurred on September 10, 2022, at approximately 2:00 a.m. Officer David Low of the Raisin Township Police Department responded to a car accident at the intersection of Sutton Road and Ridge Highway. He found a vehicle in a wooded area off the roadway, with the driver, later identified as Barton, partially pinned underneath the car.
Barton admitted to consuming alcohol earlier in the night and claimed he was on his way to a rodeo. However, it was already 2:16 a.m., well past the time any rodeo would have ended.
Medical Treatment and Blood Draw
Barton was transported to ProMedica Toledo Hospital in Toledo, Ohio, for treatment. While there, medical staff drew his blood for medical purposes, not under arrest.
Two days later, the prosecutor’s office requested the chemical analysis of Barton’s blood from the hospital.
The prosecutor’s office sent a letter to Toledo Hospital requesting that it provide Barton’s chemical analysis from September 10.
The Prosecuting Attorney for Lenawee County signed the letter. Specifically, he requested:
Please provide to the Raisin Township Police Department the complete chemical analysis of the above-named subject that was performed on or about September 10, 2022.
This request is submitted in accordance with Ohio Revised Code, 2317.02, which is attached for your reference.
This is an open and pending investigation. Please mail the records to the Raisin Township Police Department . . . (emphasis omitted).
The letter did not attach a copy of Ohio Rev Code 2317.02 as it stated.
Instead, the prosecutor’s office provided a Michigan Attorney General opinion detailing the enforceability of MCL 257.625a(6)(e) prior to a person’s arrest.
In response, Toledo Hospital sent the chemical analysis results to the police department. The chemical analysis disclosed that Barton’s blood and urine samples, which indicated a blood alcohol level of 0.23 and the presence of tetrahydrocannabinol (THC).
Legal Proceedings
The Lenawee Circuit Court initially granted Barton’s motion to suppress the blood evidence due to a perceived technical noncompliance with Michigan Compiled Laws (MCL) 257.625a(6)(e).
(e) If, after an accident, the driver of a vehicle involved in the accident is transported to a medical facility and a sample of the driver’s blood is withdrawn at that time for medical treatment, the results of a chemical analysis of that sample are admissible in any civil or criminal proceeding to show the amount of alcohol or presence of a controlled substance or other intoxicating substance in the person’s blood at the time alleged, regardless of whether the person had been offered or had refused a chemical test. The medical facility or person performing the chemical analysis shall disclose the results of the analysis to a prosecuting attorney who requests the results for use in a criminal prosecution as provided in this subdivision. A medical facility or person disclosing information in compliance with this subsection is not civilly or criminally liable for making the disclosure.
However, the prosecution later submitted evidence showing that the court’s decision relied on a factual error.
Consequently, the Michigan Court of Appeals reversed the circuit court’s decision and remanded the case.
This goes to show you can still fight a case even when you think all is lost.
If you are interested in more in depth detail read the Opinion here.
Disclaimer: This article provides a general overview, or opinions and does not substitute for legal advice. As with any law it can change or be modified and research should be done before you rely on any information provided on the internet. Although we make all attempts to link relevant laws these laws can often be gray and corrupted to fit a narrative. Anyone charged with any alleged crime should consult an attorney for specific legal guidance. Articles may be 3rd party or contain opinions and information that do not reflect the current stance of Komorn Law.
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