It was here that the Missouri Supreme Court ruled that the case of Schmerber v. California “requires more than just the dissipation of evidence of blood alcohol to support a warrantless blood draw.” Based on this ruling, the U.S. Supreme Court decided to hear this case to resolve the divide between the U.S. circuit courts of appeals and state courts. The Court decided that there are three categorical exceptions to the search warrant: incident to arrest search, arrest of motor vehicle, and consent. The Court also ruled, however, that warrantless searches carried out under threat of imminent destruction of evidence can only be exempted after examining the circumstances of the search. Thus, because McNeely's blood draw was performed under non-emergency circumstances, it was a violation of his "right to be free from unreasonable searches of his person." My thought is that if all that had to exist to demonstrate an urgent situation was an injury requiring medical evaluation, then the "special circumstance" requirement could have been met if he tripped over his shoelaces during one of his four bouts of sobriety on the field.