The 1st U.S. Circuit Court of Appeals in Boston has reversed a Maine federal court decision barring a blood alcohol test from being admitted as evidence in the prosecution of a fatal 2019 car crash that killed three people in Acadia National Park.
In an opinion issued Tuesday, the three-judge panel ruled that a Bar Harbor police officer and park ranger acted correctly when they ordered hospital staff to draw blood from the driver of the vehicle during the early morning hours of Aug. 31, 2019. The driver, Praneeth Manubolu, was the only person in the 2019 Dodge Challenger who survived the crash. His injuries were described as minor, but he was transported by a Bar Harbor police officer to a local hospital for observation.
Manubolu, 30, was subsequently charged with three counts of manslaughter for the deaths of Lenny Fuchs, 36, Laura Leong, 30, and Mohammed Zeeshan, 27, all of New York City. Manubolu, a citizen of India, was living in New Jersey at the time of the crash on Park Loop Road. Police discovered the crash scene around 3 a.m.
The four had spent the evening at a Bar Harbor tavern for dinner and drinks before going to a dance club, according to court documents. The four friends walked around “stargazing” after their night out on the town before getting into Manubolu’s car and driving to a campground in Acadia where they planned to spend the night.
First responders described the accident scene as “horrific,” according to court documents.
Last year, U.S. District Judge John Woodcock suppressed the results of the blood draw, reasoning that it was not done correctly because police did not obtain a warrant for the blood test and because no exigent circumstances existed.
Court documents show his blood alcohol content from the sample was 0.095 percent, over the legal limit of 0.08 percent in state and federal law. Federal prosecutors appealed Woodcock’s ruling, arguing that the test should be admissible in court. Prosecutors said the time involved with obtaining a warrant in a rural region like Acadia National Park would have allowed the alcohol in Manubolu’s blood to dissipate.
Federal law allows warrantless blood draws only in certain circumstances, and this case has centered on whether the government met its legal burden to draw blood from Manubolu without a warrant or his consent.
This week the appeals court overruled Woodcock, determining that the blood sample should be allowed as evidence. The case will now return to trial and the blood draw will be allowed as evidence. Manubolu is represented by Augusta attorney Walter McKee.
“I thought Judge Woodcock got it 100 percent right here. But the appeals court calls the final shots, and they shot this one down,” McKee said in a statement. “The upshot of this decision is that the whole requirement to get a warrant for a blood test is basically gone when it comes to rural Maine. Law enforcement can now just claim ‘Well, it will take too long to get a warrant out this way’ and dispense with it.”
McKee said he plans to file a petition for an en banc reconsideration of the 1st Circuit Court ruling, so that all nine judges can review the decision.
The 1st Circuit’s 44-page opinion described the warrant process as “onerous.”
The court said every warrant application must be submitted in writing and approved by a supervisor or the District Attorney’s Office. Warrants also require officers to swear before a judge or justice of the peace, a process the court estimated could have taken three to five hours. First responders were busy that morning between 3-4:30 a.m. trying to identify the victims, reconstruct the accident scene and attempt to obtain a warrant for a blood draw from the United States Attorney’s Office.
“The nature of the crash and the fact that the officers were not twiddling their thumbs weighs in favor of there being exigent circumstances,” the 1st Circuit wrote in its opinion.
Court documents show Manubolu has been released on bail, and the conditions of his release allow for home detention. The judge has since amended those conditions to allow him to move to Georgia for a new job.
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