State v. Spencer
In State v. Spencer, 235 Ariz. 496, 4989, 333 P.3d 823, 825 (App. 2014) the defendant "steadfastly refused medical treatment.
She capitulated only after being told by a police officer she would be arrested if she did not go to the hospital." 235 Ariz. at 499-50015, 333 P.3d at 826-27.
Given this "ultimatum," Spencer found the defendant's decision to go to the hospital (rather than jail) was "the product of coercion or duress" by the police officer and, accordingly, involuntary. 235 Ariz. at 499-500 14, 16, 333 P.3d at 826-27.
Thus, Spencer held that the police officer's directive to either go to jail or go to the hospital removed from the defendant the ability to voluntarily refuse medical care. Id. at 50016, 333 P.3d at 827.