Birchfield v. North Dakota

Birchfield v. North Dakota

Birchfield v. North Dakota is a significant United States Supreme Court case that addressed the constitutionality of warrantless blood tests in the context of drunk driving arrests. The decision, delivered on June 23, 2016, clarified the limits of implied consent laws and the Fourth Amendment rights of individuals suspected of driving under the influence (DUI).

Background

The case consolidated three separate cases involving drivers who were arrested for DUI and subjected to chemical tests to determine their blood alcohol concentration (BAC). The primary legal question was whether states could criminalize the refusal to submit to a blood test without a warrant.

The Cases

1. Birchfield v. North Dakota: Danny Birchfield was arrested for DUI and refused a blood test. He was charged with a crime for his refusal under North Dakota law. 2. Bernard v. Minnesota: William Bernard was arrested for DUI and refused a breath test. He was charged with a crime for his refusal under Minnesota law. 3. Beylund v. Levi: Steve Beylund consented to a blood test after being informed that refusal was a crime. He later challenged the test as an unconstitutional search.

Supreme Court Decision

The Supreme Court, in a 7-1 decision, held that:

• Warrantless breath tests are permissible under the Fourth Amendment as a search incident to a lawful arrest for drunk driving.
• Warrantless blood tests are not permissible under the Fourth Amendment, as they are more intrusive than breath tests.
• States cannot criminalize the refusal to submit to a blood test without a warrant.

Justice Samuel Alito delivered the opinion of the Court, emphasizing the difference in intrusiveness between breath and blood tests.

Implications

The decision in Birchfield v. North Dakota has significant implications for law enforcement and DUI laws across the United States. It requires states to adjust their implied consent laws to align with the constitutional protections outlined by the Court.

Also see

• Fourth Amendment to the United States Constitution
• Implied consent laws
• Drunk driving in the United States
• Search incident to a lawful arrest