Doyle v. State

The deputy was not required to read Miranda warnings prior to requesting consent to administer field sobriety tests because, although he took the defendant's license and proof of insurance as part of the initial traffic stop, a reasonable person would conclude that the detention was only temporary.

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Following a bench trial, Robert Doyle was convicted of both driving under the influence of alcohol to the extent he was a less safe driver1 and of per se driving under the influence of alcohol.2 He appeals, arguing that the trial court erred i in denying his motion to suppress the results of field sobriety tests and ii in admitting the results of the state-administered chemical test without first proving his consent. For the reasons set forth below, we affirm. “When reviewing a trial court’s decision on a motion to suppress, this court’s responsibility is to ensure that there was a substantial basis for the decision. The evidence is construed most favorably to uphold the findings and judgment, and the trial court’s findings on disputed facts and credibility are adopted unless they are clearly erroneous.” Punctuation omitted. Turner v. State .3 Furthermore, “since the trial court sits as the trier of fact, its findings are analogous to a jury verdict and will not be disturbed if there is any evidence to support them.” Morgan v. State .4 “The trial court’s application of the law to undisputed facts is subject to de novo review.” Punctuation omitted. Buchnowski v. State .5

So construed, the evidence demonstrates that one night in December 2004, a Hall County deputy pulled Doyle over for speeding. Upon approaching Doyle’s vehicle to request that he produce his license and proof of insurance, the deputy detected the odor of an alcoholic beverage. Consequently, the deputy asked Doyle to exit his vehicle, and as he did so, the deputy noticed that Doyle’s eyes appeared watery and bloodshot. The deputy then asked Doyle if he had consumed any alcoholic beverages that night, and Doyle replied that he had.

Doyle v. State

The deputy was not required to read Miranda warnings prior to requesting consent to administer field sobriety tests because, although he took the defendant's license and proof of insurance as part of the initial traffic stop, a reasonable person would conclude that the detention was only temporary.

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