State v. Abdullahi (85874-2) - Cuffs but not Custody & Meth Contamination Abatement

Alright folks, this week COA-I released a long-awaited opinion in King County's State v. Abdullahi (Jun. 23, 2025, 85874-2).  This opinion arises from a felony Physical Control case in King County where officers encountered a vehicle stopped in traffic with an apparent impaired driver behind the wheel.  The defendant made some initial incriminating statements and, after officers extricated him and placed him in cuffs for safety reasons, the dialog between the parties continued.  A blood draw was eventually completed and analyzed by the tox lab.

This opinion is worth reading for a few reasons:  The discussion on the Miranda custody analysis is a great reminder to some of our courts of limited jurisdiction which can forget that cuffs are not de facto custody and that safety concerns greatly weigh on the calculous.  Additionally, it wasn't an abuse of discretion for the trial court to find a lack of resulting prejudice in the State's tardy disclosure of a government contamination abatement recommendation letter.  Further, the panel lends credence to the significant efforts that our tox lab undertook to abate the contamination exclusive from the recommendations in that letter.

One brief comment from the panel which was made during oral argument and noted in this opinion is the fact that the State chose not to cross-appeal the trial court's findings associated with the import of the abatement letter and the recommendations contained therein.  At oral argument, the panel expressed some skepticism that the recommendations in that letter should be given the weight that they were given since there was no inquiry into whether the drafters of that letter possessed any sort of forensic toxicology credentials.  This is important since the defense tends to use this letter as some sort of legitimate standard of care (though lacking any real scrutiny).  This is an appellate practice point to note for later - if we're going to dance, let's dance the whole number and cross-appeal on unfavorable findings where we can preserve the issue.

Read the opinion HERE - > 858742.pdf