South Dakota v. Neville
Headline: Court allows states to use a driver’s refusal to take a blood-alcohol test as trial evidence, reversing the state court and making it easier for prosecutors to show possible intoxication.
Holding: The Court held that a suspect’s refusal to take a lawfully requested blood-alcohol test is not compelled testimony and may be admitted as evidence, so using refusal statements does not violate the Fifth Amendment.
- Allows prosecutors to present a driver’s refusal as evidence at trial.
- Makes refusing a test riskier by permitting use of refusal statements.
- Supports license suspension penalties alongside trial evidence.
Summary
Background
A South Dakota man was stopped after running a stop sign, failed field sobriety tests, and was arrested. Officers read Miranda warnings and asked him to take a blood-alcohol test from a printed card; he said, “I’m too drunk, I won’t pass the test,” and refused. South Dakota law allowed evidence of such refusals at trial and allowed license revocation for refusal, but state courts suppressed the refusal evidence as violating the privilege against self-incrimination.
Reasoning
The core question was whether a suspect’s refusal to take a blood-alcohol test is protected as compelled testimony. The majority relied on earlier law holding that forced blood tests themselves are physical, not testimonial, evidence and emphasized that the Fifth Amendment bars only compelled statements or testimony. Because the suspect was given a lawful choice to submit or refuse and the refusal was not the product of government coercion, the Court held the refusal could be admitted. The Court also rejected a separate due-process argument that the officer’s warnings implicitly promised silence would be safe.
Real world impact
The ruling allows states to introduce a driver’s refusal to take a requested chemical test as evidence of possible intoxication and supports state penalties like license suspension for refusal. It does not disturb limits where true coercion, extreme procedures, or strong religious objections make a test or its alternatives inappropriate. The decision reverses the South Dakota Supreme Court and sends the case back for further trial proceedings consistent with this opinion.
Dissents or concurrances
Justice Stevens (joined by Justice Marshall) dissented, arguing the U.S. Supreme Court lacked jurisdiction because the state court had rested its judgment on an independent state constitutional ground and thus the federal decision was unnecessary.
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