The trial court properly granted defendant’s motion to suppress challenging the State’s seizure and search of vials of his blood drawn at a hospital for medical purposes. The government’s testing constituted a warrantless search of his blood sample in violation of the Fourth Amendment and no exception to the warrant requirement applied. State v. Martinez, 2019 Tex. Crim. App. LEXIS 237 (Mar. 20, 2019).
The affidavit for defendant’s search warrant failed to show probable cause, and the search had to be suppressed. The officers received information from a CI but days of surveillance were unproductive. They applied for a search warrant anyway. Looking at the four corners of the affidavit, probable cause was lacking. Valentine v. State, 2019 Del. LEXIS 142 (Mar. 20, 2019).*