Arizona v. Butler, 302 P.3d 609 (Ariz. Sup. Ct. 2013)

The Arizona Supreme Court ruled the juvenile court did not abuse its discretion when it found a 16-year old youth’s consent to a warrantless blood draw was involuntary and granted his motion to suppress.

The court offered the following language in support:
“We hold now that, independent of § 28-1321, the Fourth Amendment requires an arrestee’s consent to be voluntary to justify a warrantless blood draw. If the arrestee is a [youth], the youth’s age and a parent’s presence are relevant, though not necessarily determinative, factors that courts should consider in assessing whether consent was voluntary under the totality of the circumstances.”