State v. Doyle
While police never expressly informed the defendant that he was free to leave the scene of an accident, Connecticut law imposes no such affirmative obligation on law enforcement personnel; rather, whether a defendant is specifically apprised of the right to leave is but one consideration in the totality of circumstances analysis of whether he was seized. Following a jury trial, Christopher Doyle was found guilty of operating a motor vehicle while under the influence of intoxicating liquor and acquitted of other charges stemming from an incident in which the vehicle Doyle was driving veered off the road and struck Donald Schaus standing in his driveway. Doyle pleaded guilty under a part B information and appealed claiming that the court abused its discretion in denying his motions to suppress evidence of his blood test. The Appellate Court affirmed the judgment. The totality of the circumstances established that Doyle's consent to a blood test following his standard performance on field sobriety tests was free and voluntary. Testimony indicated that Doyle was then 24 years old, literate and a university student. He was afforded the opportunity to review the standardized consent form prior to signing it. No evidence indicated that police coerced or threatened Doyle. After the preliminary investigatory detention culminating in field sobriety tests, which detention the defendant conceded was proper, he moved freely about the scene without restraint or restriction. The defendant provided written consent to the blood test twice, once with his father at the scene and once with his mother at the hospital. Further, the blood test did not result from an unconstitutional seizure. The defendant unsuccessfully contended that the test resulted from an illegal investigative detention and that the failure of police to inform him he was free to leave after field sobriety tests led him to believe he was not free to leave. Speaking with the defendant was but one aspect of police efforts at the chaotic scene of the catastrophic accident. The totality of the circumstances indicated that a reasonable person would have believed he was free to leave following field sobriety tests. Even if a reasonable person would not have believed he was free to leave, the defendant could not prevail. An investigative detention was found warranted under the totality of the circumstances.