State v. Onumonu
In State v. Onumonu, 2001 WL 695539, (Del. Super. Jun. 5, 2001), medical personnel at Christiana Hospital performed a blood draw and resultant analysis following a three-car collision involving the defendant.
Christiana Hospital voluntarily released the results of the blood draw to the police. The defendant sought to suppress the evidence obtained from the blood draw, which occurred for the sole purpose of medical treatment.
The Onumonu court held that "because there was no State involvement in the withdrawal and testing of Defendant's blood or in its disclosure to police, there were no Fourth Amendment intrusions into Defendant's right to privacy."
However, the Onumonu court noted that, "in contrast, any such evidence which is obtained at the request of, or with the involvement of, law enforcement officials is subject to Fourth Amendment constraints."
The Court held that Christiana Hospital's disclosure of the defendant's blood test results to the police did not violate the defendant's Fourth Amendment right to privacy because law enforcement played no role in the hospital's decision to turn over the results to police.