Judge denies motion to suppress warrantless blood draw in State v. Singleton

Judge David Booth denied a defense motion to suppress a warrantless blood draw in State of Tennessee v. Nicholas Singleton after a hearing in Prince County Circuit Court, finding the trooper had sufficient probable cause and that Singleton’s consent was knowing and voluntary.

The motion, filed by the defense, alleged Trooper Worley lacked probable cause to seek a blood draw and that the implied-consent process was not a knowing, voluntary waiver. The defense argued the officer’s report contained clerical errors, that she did not detect the odor of alcohol and that her observations did not rise to probable cause. Assistant prosecutors cited State v. Reynolds and related Tennessee precedent in arguing that probable cause is a fact-specific determination and that the totality of circumstances here justified the request for blood.

Trooper Worley, a trooper with the Tennessee Highway Patrol, testified she responded after dispatch advised of a single-vehicle crash on Highway 70 near New Johnsonville in Humphreys County and later made contact with Nicholas Singleton at 3 Rivers Hospital. Worley said she spoke with Singleton, performed a horizontal gaze nystagmus (HGN) check (the admissibility of which the defense challenged), showed him the blood kit and read the implied-consent form on camera. Worley testified she “did” watch him sign the form and that she submitted the collected blood to the Tennessee Bureau of Investigation (TBI) for analysis.

Singleton spoke on the record at length; in courtroom remarks he stated, “I had 8 beer,” while Trooper Worley and other testimony recorded that Singleton also volunteered he had had “one beer” during her interaction. Defense counsel emphasized that the officer did not smell alcohol and that the crash was a single-vehicle incident with no other injured parties, arguing those facts weighed against probable cause and against a finding that consent was knowing and voluntary.

The defense also objected when the state sought to introduce HGN-test observations without qualifying the trooper as an expert; the court sustained at least one objection to expert scientific testimony on the HGN results. The state argued probable cause was supported by the serious crash, the defendant’s injury, the officer’s observations (including watery eyes and disoriented or inconsistent answers) and the defendant’s statements about drinking, taken together.

In a detailed ruling, Judge Booth said the officer’s in-person observations — including the crash circumstances, the defendant’s appearance and statements — provided a factual basis that justified asking for a blood test. The judge also reviewed the implied-consent warning, the circumstances under which it was read on body-worn camera and Singleton’s signature on the form, and concluded the record did not show coercion. The court stated that, while the officer did not smell alcohol, that fact alone did not negate the other circumstances relied on. The court found that “there was some probable cause” and that Singleton’s consent was a knowing, voluntary waiver; the judge therefore denied the motion to suppress.

The court received two items into evidence: the body-worn camera footage (admitted as Exhibit 1) and the implied-consent form with Singleton’s signature (admitted as Exhibit 2). The judge directed the parties to prepare a written order reflecting that the motion was heard and dismissed and discussed setting a status/trial date; the matter was to be placed on the court’s calendar on June 20 for further scheduling.

The ruling preserves the blood evidence for the state; defense counsel indicated they would revisit suppression arguments on appeal if appropriate. No trial outcome on guilt or innocence was reached during the hearing.