State v. May
In State v. May, 210 Ariz. 452, P 9, 112 P.3d 39, 42 (App. 2005), a police phlebotomist drew May's blood while he stood at the rear of the officer's car, with his arm resting on the car's trunk. Id. P 7. In the trial court, an expert witness opined that standing blood draws increase the risk of injury and violate the applicable standard of care. Id.
The trial court nonetheless found the blood draw reasonable because the procedure "resulted in only a 'slightly higher' risk of complications 'in a field setting' than those of a clinical setting." Id. P 8.
On review, the Court found no constitutional or statutory basis to disturb the trial court's ruling, noting that the training the officer had received and his experience in having previously "drawn blood 150 to 200 times," id. P 10, ensured that the procedure was reasonable. Id. PP 9-10.