A federal appeals court has reversed a lower court decision and determined that the results of a blood test taken by police as they investigated the deadliest crash ever in Acadia National Park should be admissible in court.
Last year, U.S. District Court Judge John Woodcock ruled that police did not follow proper procedure in obtaining a blood test from Praneeth Manubolu, who is accused of driving a car that crashed on the Park Loop Road in the early morning hours of Aug. 31, 2019. Three passengers in Manubolu’s new Dodge Challenger died in the crash.
Woodcock barred the test results, which showed that Manubolu’s blood alcohol content was above the legal limit, because police did not obtain a warrant to collect the evidence before having Manubolu’s blood drawn.
Federal prosecutors had argued that the evidence should be admissible because if police had gone through the long process of obtaining a warrant, evidence about Manubolu’s blood-alcohol content would have been “destroyed” by the natural dissipation of alcohol in the defendant’s bloodstream.
The situation created “exigent” circumstances that allowed police to test Manubolu’s blood without first getting a warrant, they said. Those circumstances included being unable to get in touch with federal prosecutors, having other immediate tasks to tend to and being unable to draft the needed warrant application paperwork while at the accident scene.
On Tuesday, the federal First Circuit Court of Appeals in Boston agreed with federal prosecutors, and ruled that Manubolu’s blood test results should be admissible in court. Ranger Brian Dominy, who investigated the crash on behalf of Acadia National Park, reasonably believed that “exigent circumstances existed” in obtaining the evidence, the panel of three judges decided.
“Ranger Dominy felt there was simply too much valid police work to be done before he could leave the scene to draft a warrant affidavit,” O. Rogeriee Thompson, one of three judges on the panel, wrote in the decision. “Given the totality of the circumstances, the government has met its burden to show it was reasonable for Ranger Dominy to think exigent circumstances existed” and thereby justified collecting a blood sample from Manubolu before getting a warrant.
Manubolu’s attorney, Walter McKee of Augusta, said he thought Judge Woodcock’s decision was “100 percent right,” but the appeals court decision is the one his client has to contend with.
“The upshot of this decision is that the whole requirement to get a warrant for a blood test is basically gone when it comes to rural Maine,” McKee said. “Law enforcement can now just claim ‘well it will take too long to get a warrant out this way’ and dispense with it.”
The legal limit for blood-alcohol content for anyone driving a motor vehicle in Maine, and in Acadia National Park, is 0.08 percent. Manubolu’s blood-alcohol content from the warrantless test was 0.095 percent, according to court documents.
Manubolu, 30, has been charged with three counts of manslaughter for the deaths of Lenny Fuchs, 36, Laura Leong, 30, and Mohammad Zeeshan, 27, all of New York City.
A citizen of India who at the time was living in New Jersey, Manubolu had met up with the trio the day before at Smuggler’s Den Campground in Southwest Harbor after making arrangements via Meetup, an app that connects members with mutual interests. That evening Fuchs, Leong and Zeeshan rode with Manubolu to Bar Harbor to get a late dinner and then, after going to a dance club, decided to drive into the park, where the crash occurred.
Manubolu was released from custody on Sept. 20, 2019, on $7,500 bail and, since October of that year, has been living and working in the Atlanta area. He has surrendered his Indian passport to the court to help ensure that he does not leave the country while awaiting trial. A trial date has not been set.
The circumstances under which police officers are permitted to take blood samples from drivers without first getting a warrant have prompted recent appeals of similar cases at both the state and federal court levels.
In 2019, a state judge in Hancock County threw out the results of a blood test taken from a driver in a fatal crash in Eastbrook, saying that police failed to get a warrant for the test and were not justified in getting a blood sample without one.
That same year, the Maine Supreme Judicial Court heard oral arguments concerning the admissibility of a blood sample obtained from a trucker from Tennessee who was convicted of causing a 2016 crash that killed two people on Route 17 in the Knox County town of Washington. In 2020, the state supreme court ruled that a state law that mandated a blood draw from drivers in fatal accidents was unconstitutional because it did not require police to obtain warrants before collecting blood from drivers who did not consent to the test.
However, also in 2019, the U.S. Supreme Court ruled that police can obtain a blood sample without a warrant from drivers who are unconscious and who are suspected of driving under the influence of alcohol, or if exigent circumstances require that police obtain a sample quickly.