THE STATE OF FLORIDA
v.
BRITTANY A. EVANS

Fla. 3d DCA | 2023-08-16
No. 22-0809
Florida District Court of Appeal, Third District (2023)

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Holding

Suppression of a breathalyzer test is proper when law enforcement fails to render reasonable assistance to an arrestee who requests an independent blood alcohol test.


Headnotes

[1] Suppression of breathalyzer test results is a proper sanction when law enforcement fails to provide reasonable assistance to an arrestee requesting an independent blood a…

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Key Quotes

“approving suppression of breathalyzer test results as a proper sanction where the arrestee's right to an independent blood alcohol test has been frustrated by law enforcement's failure to render reasonable assistance to such person in obtaining the test”

Citation to Unruh v. State, discussing the appropriate remedy for law enforcement's interference with independent testing rights.

Facts & Procedural History

Brittany A. Evans was arrested and underwent testing for blood alcohol content. The defendant sought an independent blood test but law enforcement fai…

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Opinion of the Court

PER CURIAM.

Affirmed. Unruh v. State, 669 So. 2d 242, 245 (Fla. 1996) (approving suppression of breathalyzer test results as a proper sanction where the arrestee's right to an independent blood alcohol test has been frustrated by law enforcement's failure to render reasonable assistance to such person in obtaining the test); State v. Durkee, 584 So. 2d 1080, 1081, 1083 (Fla. 5th DCA 1991) (reinstating the suppression order of the county court and noting that Durkee, in addition to consenting to the breathalyzer test, “repeatedly” asked to have a blood test).


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