Missouri Court of Appeals, Eastern District / May 19, 2020
Jena Rae Haffner, Respondent, vs. Director of Revenue, State of Missouri, Appellant.
Jena Rae Haffner's driver's license was suspended after she was involved in a car accident and a blood test revealed a high blood alcohol content. The trial court rescinded the suspension, finding she was not arrested at the time she consented to the blood draw. The Director of Revenue appealed. The appellate court reversed and remanded, holding that Haffner was indeed arrested, both by actual physical restraint due to her injuries and by her submission to the officer's authority after being informed of the implied consent warning and license revocation consequences.