Pennsylvania DUI Lawyers Blog
In DUI trials, proper jury instructions are essential to ensuring a fair trial and guiding jurors through the applicable legal standards. As such, disagreements over jury instructions can lead to unjust outcomes, and may be grounds for pursuing an appeal, as illustrated in a recent Pennsylvania case. If you are facing DUI charges in Pennsylvania, it is critical to work with a Pennsylvania DUI defense attorney who can assert all relevant procedural and constitutional protections on your behalf.
It Is Reported That the Defendant Refused a Blood Draw Despite a Valid Warrant
It is reported that in October 2022, a police officer encountered the defendant near a parked vehicle in the roadway with its hazard lights on. The officer allegedly observed signs of alcohol impairment, conducted field sobriety tests, and arrested the defendant for DUI. The officer transported the defendant to a DUI processing center and read him the Pennsylvania DL-26 form, advising him of the consequences of refusing a chemical test. The defendant refused to submit to a blood draw.
It is further reported that the officer obtained a search warrant for a blood sample and returned with the defendant to the processing center. The officer showed the defendant the warrant but did not allow him to physically read or handle it. The defendant again refused the blood draw. Rather than compel compliance, the officer charged the defendant with obstruction of the administration of law under 18 Pa.C.S.A. § 5101, citing the refusal to comply with a valid warrant.
Allegedly, at trial, the defendant reportedly requested that the court instruct the jury with a proposed charge based on a quote from an 1884 Pennsylvania case, suggesting that officers executing a warrant must allow the person subject to it to examine the warrant upon request. The trial court declined to provide the instruction and instead used the standard jury instruction for obstruction. The jury convicted the defendant of obstruction and DUI, and the defendant subsequently appealed.
Jury Instructions in Pennsylvania DUI Cases
The trial court’s decision to deny the requested jury instruction was reviewed for legal error or abuse of discretion. Pennsylvania law grants trial courts substantial discretion in determining whether proposed jury instructions are warranted. The standard requires the proposed instruction to be both an accurate statement of law and relevant to the facts and legal issues in the case.
The court determined that the defendant’s proposed instruction, relying on dicta from a 19th-century case addressing warrantless arrests, was inapplicable. The historical case addressed an officer’s obligation to inform an arrestee of the cause of arrest, not to permit inspection of a search warrant related to the collection of physical evidence. The trial court emphasized that the case did not address modern search and seizure law and had no bearing on the obstruction statute under which the defendant was charged.
Under Pennsylvania law, to convict a person of obstruction, the Commonwealth must prove that the defendant intentionally interfered with a governmental function through physical means or unlawful conduct. The jury was instructed accordingly. The court noted that the defendant was shown the warrant and told its purpose, and that refusal to comply with a valid warrant, even if the individual is not handed the document, can constitute obstruction.
The court concluded that the defendant was not entitled to a new trial, as the proposed instruction was both legally incorrect and irrelevant to the elements of obstruction. The judgment of sentence was therefore affirmed.
Meet with a Dedicated Pennsylvania DUI Defense Attorney
A DUI arrest can lead to serious charges beyond impaired driving, especially when issues of warrant compliance and obstruction are involved. If you are charged with a DUI, it is critical to understand your rights, and you should talk to an attorney as soon as possible. Attorney Zachary B. Cooper is a dedicated Pennsylvania DUI defense lawyer who understands how to challenge charges based on improper police procedures or unfair trial practices. To schedule a confidential consultation, contact Mr. Cooper via the online form or call (215) 542-0800.