State v. Lawrence Robinson
In State v. Lawrence Robinson, 2006 WL 1148477, (Del. Super. May 1, 2006) Christiana Hospital drew blood from the defendant for medical purposes.
However, in that case, the investigating officer specifically left the hospital, obtained a warrant for the results of the blood draw, and returned for the records after obtaining a warrant.
Thus, the Superior Court found that the State had complied with the Fourth Amendment.
In denying the defendant's motion to suppress the results of the blood draw based on this information, the Superior Court noted, "because there is no evidence to suggest that the police or other governmental agents compelled the hospital to analyze defendant's blood, or otherwise requested the hospital's performance of the blood alcohol content test, the Fourth Amendment was not implicated in this case."