Walker v. City of Lynchburg

BENTON, Judge,

dissenting.

The evidence proved that Walker was cooperative during the procedure and did not interfere with the taking of his blood. The Commonwealth has the burden of establishing a “valid reason for the lack of availability of [the blood] test.” Breeden v. Commonwealth, 15 Va.App. 148, 151, 421 S.E.2d 674, 676 (1992). The technician’s testimony that she could not *201locate a vein from which to draw blood was insufficient to prove the test was unavailable under Code § 18.2-268.2. The record proved that the officer failed to inquire whether a qualified physician or nurse was available in the hospital’s adjacent emergency room to withdraw blood from Walker. I would hold that the police officer unreasonably made the medical judgment that the sample of blood could not be taken for the test.