State v. Shirley

In 2006, Rachel Shirley (defendant) ran a stop sign and flipped her car. Shirley’s passenger later died at the hospital. According to police, Shirley informed police at the accident scene that she had drunk alcohol before driving. After learning that Shirley’s passenger died, police directed the hospital to obtain blood samples from Shirley so that the crime laboratory could test Shirley’s blood-alcohol content. A grand jury indicted Shirley for vehicular homicide under the influence of alcohol. Shirley filed a motion to suppress. The only witness to testify the suppression hearing was a forensic scientist who testified about Shirley’s blood-alcohol-test results. Shirley argued that the blood-alcohol testing failed to comply with Louisiana’s statutory guidelines for administering blood-alcohol tests, which required that blood must be drawn by a qualified person who is a physician, registered nurse, qualified technician, or chemist. The prosecution (plaintiff) failed to produce any testimony or other evidence about the person who had drawn Shirley’s blood at the hospital. The trial court granted Shirley’s motion to suppress the blood-alcohol-test results and other evidence. The prosecution appealed, and the appellate court affirmed. The Louisiana Supreme Court granted the prosecution’s writ application to evaluate the trial court’s suppression of Shirley’s blood-alcohol-test results and other evidence.