In People v. Deltoro (1989) 214 Cal. App. 3d 1417, after an automobile accident a CHP officer obtained a blood sample from a defendant who was in the hospital. The officer did not have a warrant and the defendant was not placed under arrest at the time of the extraction of the blood. The appellate court concluded that where there is probable cause "the taking of such person's blood is valid regardless of whether that person is first placed under arrest." ( Id., at p. 1425.)