STATE OF FLORIDA, PETITIONER,
v.
JAMES A. ADAMS, RESPONDENT
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Blood-alcohol test results obtained during an accident investigation are admissible in criminal prosecutions, even if the investigation phase has not yet begun.
[1] Blood-alcohol test results obtained during the accident-report phase of a police investigation are admissible in criminal prosecutions.
[2] Florida's constitutional protection against self-incrimination does not require the suppression of blood-alcohol test results obtained during an accident investigation.
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Join FLexlaw to unlock all legal intelligenceJames Adams was charged with manslaughter by operation of a motor vehicle while intoxicated. The trial court denied his motion to suppress blood-alcoh…
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McDONALD, Justice.
We have for review Adams v. State, 448 So. 2d 1201 (Fla. 3d DCA 1984), which expressly construes a provision of the state constitution. We have jurisdiction. Art. V, § 3(b)(3), Fla. Const. We quash Adams.
The state charged James Adams with manslaughter by operation of a motor vehicle while intoxicated. The trial court denied Adams’ motion to suppress the results of a blood-alcohol test made during the accident-report phase of the police investigation. A jury convicted Adams as charged, and he appealed the denial of suppression. The district court reversed and remanded for a new trial, holding that subsection 316.066(4), Florida Statutes (1981), as well as the state constitutional protection against self-incrimination, required suppression of a blood-alcohol test made as part of the accident investigation report before the criminal investigation has begun. The district court relied on State v. Coffey, 212 So. 2d 632 (Fla.1968), and State v. Mitchell, 245 So. 2d 618 (Fla.1971), to support its holding.
The state contends that Brackin v. Boles, 452 So. 2d 540 (Fla.1984), should control this case. We agree. In Brackin we observed that there is no federal or state constitutional bar to the admission of blood-alcohol test results in civil or criminal prosecutions. We receded from the distinctions drawn in Coffey and Mitchell between blood-alcohol tests done for purposes of accident report preparation and those done for criminal investigations. All such test results are admissible because blood-alcohol tests are not communications privileged under subsection 316.066(4). Brac-kin involved a civil prosecution, but the principle applies with equal force to the criminal prosecution in this case. The trial court correctly refused to suppress the blood-alcohol test results.
Accordingly, we quash Adams and remand for further proceedings consistent with this opinion.
It is so ordered.
BOYD, C.J., and ADKINS, OVERTON, ALDERMAN, EHRLICH and SHAW, JJ., concur.
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Johnson v. Fla. Farm Bureau Cas. Ins. Co., 542 So. 2d 367 (Fla. 4th DCA 1988)…la.1981). The trial court would not allow punitive damages to be reconsidered because of the previous partial judgment, despite the consideration that under Brackin v. Boles, the basis for the former ruling had become erroneous. See State v. Adams, 466 So. 2d 1067 (Fla.1985); Hartford Accident and Indemnity Co. v. Ocha, 472 So. 2d 1338 (Fla. 4th DCA), rev. denied, 478 So. 2d 54 (Fla.1985). The successor judge erred in concluding that the previous decision on this subject was the law of the case. A denial of c…
Authorities Cited
- Brackin v. Boles, 452 So. 2d 540 (Fla. 1984)
- State v. Mitchell, 245 So. 2d 618 (Fla. 1971)
- State v. Coffey, 212 So. 2d 632 (Fla. 1968)
- Adams v. State, 448 So. 2d 1201 (Fla. 3d DCA 1984)