Are Oral Statements of Medical Personnel and Blood-Alcohol Test Admissible to Establish Probable Cause for Arrest ?

In Village of Arlington Heights v. Bartelt, 211 Ill. App. 3d 747, 750, 156 Ill. Dec. 192, 570 N.E.2d 668 (1991), the court held that, although blood-alcohol tests may be admitted at trial pursuant to section 11--501.4 of the Illinois Vehicle Code ( 625 ILCS 5/11--501.4 (West 1998)), there was no specific authority permitting the use of oral statements made by medical personnel to establish probable cause. Bartelt, 211 Ill. App. 3d at 750. The defendant argued that the results of the blood tests performed on January 31, 1998, were protected under the physician-patient privilege ( 735 ILCS 5/8--802 (West 1998)) and that the officers needed some other independent basis to establish probable cause. In response to the motion to reconsider, the State argued that section 11--501.4--1 of the Code ( 625 ILCS 5/11--501.4--1 (West 1998)) permitted the use of blood-alcohol test results to establish probable cause for arrest. The State argued that section 11--501.4--1 specifically authorized medical personnel to report the results of blood tests to the Department of State Police or local law enforcement agencies. 625 ILCS 5/11--501.4--1 (West 1998).