Search and Seizure • Blood Draw • Implied Consent • Criminal Penalties

Commonwealth v. Haines, PICS Case No. 17-1291 (Pa. Super. Aug. 2, 2017) Moulton, J. (15 pages).

The court could not determine if the trial court erred in finding that defendant’s consent to a blood draw was involuntary where it failed to make factual findings regarding whether defendant consented to the blood draw before or after being improperly warned of the criminal consequences of refusal. The court reversed a trial court suppression order and remanded.