A federal appeals court will decide whether investigators needed a warrant to take a blood sample from the driver in a 2019 crash that killed three people in Acadia National Park.
Praneeth Manubolu has been indicted on three counts of manslaughter, two counts of operating under the influence and one count of unsafe operation. Court documents show his blood alcohol content from the sample was 0.095 percent, over the legal limit of 0.08 percent in state and federal law.
Praneeth Manubolu challenged the blood test that was taken after the car he was driving in Acadia National Park early on Aug. 31, 2019, went off Park Loop Road, killing his three passengers. He argues the state-mandated blood sample shouldn’t have been taken because the accident occurred on federal land. National Park Service photo
Federal law allows warrantless blood draws only in certain circumstances, and this case has centered on whether the government met its legal burden to draw blood from Manubolu without a warrant or his consent. A judge in the U.S. District Court of Maine said no and decided the test result was inadmissible, and the federal prosecutor took the case to the 1st Circuit Court of Appeals in Boston. A panel of appellate judges heard oral arguments Monday, and they do not have a timetable to issue a decision.
The judges seemed particularly interested in the apparent breakdown in the process for getting a warrant that night. Court documents show a National Park Service ranger called at least two federal prosecutors before finally reaching a third.
Assistant U.S. Attorney Julia Lipez argued that the process of getting the warrant would have taken hours even if the prosecutor on call had responded promptly. She said investigators were within the law to take the blood sample without a warrant because of the serious circumstances surrounding the crash and the possible dissipation of alcohol from the driver’s bloodstream.
“If the warrant process works 99 times out of 100, but that hundredth time, it’s not sufficient given the circumstances of whatever is being investigated, that is the case where the exigency exception applies,” Lipez said. “And I would submit that’s what we have here. There’s nothing in the record to suggest that this warrant process doesn’t typically work.”
Defense attorney Walt McKee argued that the process itself was too cumbersome, and the situation did not meet the emergency standards set by the U.S. Supreme Court to bypass a warrant. He recalled the order of District Judge John Woodcock, who threw out the blood test in this case last year. Woodcock found that the time it takes to obtain a warrant through a process set out by the U.S. Attorney’s Office cannot be a “de facto end run” around the law.
“It’s going to simply take too long using their procedure in the first place,” McKee said.
Police said Manubolu was driving a car on the Park Loop Road in the early hours of Aug. 31, 2019, when it rolled over and crashed into trees, killing his three passengers. He is being prosecuted in federal court because the crash happened in a national park.
Park officials identified the victims as Lenny Fuchs, 36, Laura Leong, 30, and Zeeshan Mohammed, 27, all of New York City.
Manubolu was 28 and living in New Jersey at the time of the crash. Court documents show he was released on bail, and his conditions of release allow for home detention. The judge has since amended those conditions to allow him to move to Georgia for a new job.
Federal and state courts have addressed the constitutional requirements for taking blood samples in suspected drunken-driving cases.
In 2013, the U.S. Supreme Court ruled that people suspected of drunken driving cannot automatically be subjected to a blood test. But the justices said each case needs to be considered individually, so law enforcement officers still have the option to draw blood without a warrant in exigent circumstances.
Last year, the Supreme Court issued another ruling related to warrantless blood draws, this time saying police can take a sample from an unconscious person suspected of driving under the influence. Manubolu did not lose consciousness, so Woodcock did not rely heavily on that case in his decision.
In a 2018 case in Maine, District Judge Brock D. Hornby blocked the use of a blood test taken from a fishing boat captain who was charged with seaman’s manslaughter in the deaths of his two crew members. They died when his lobster boat sank in 2014, and a warrantless blood test showed the captain had ingested marijuana and oxycodone. The judge decided the test would only be admitted at trial if the captain testified that he had not used drugs, and the man ultimately pleaded guilty in exchange for a four-year prison sentence.
The U.S. Attorney’s Office also appealed the judge’s decision in that case. But the 1st Circuit never ruled on that case because the prosecutors withdrew the appeal.
At the time of the crash, Maine had a state law in place requiring that a blood sample be taken from any driver in an accident with serious injury or death. No warrants were required.
Court documents show a local police officer cited that law when he arranged the blood draw at Mount Desert Island Hospital even though Manubolu did not consent and a judge had not yet signed a warrant. But the federal court later found that the state law did not apply in this case. The Maine Supreme Judicial Court has since struck down that state law as unconstitutional.
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