1. Where a driver's medical condition precludes a reasonable opportunity
to administer a breath test, does the Fourth Amendment always permit
a warrantless blood draw without the court's consideration of whether
the police could have reasonably obtained a warrant without interfering
with other pressing needs or duties?

2. Whether the California Court of Appeal's published decision
interpreting this Court's decisions in Missouri v. McNeely (2013) 569
U.S. 141, 148 [133 S.Ct. 1552, 185 L.Ed.2d 696] (" McNeely "), and
Mitchell v. Wisconsin (2019) ___U.S.___ [139 S.Ct. 2525, 204 L.Ed.2d
1040] (" Mitchell ") as always permitting a warrantless blood draw where
a driver is unconscious and needs medical aid without consideration of
the totality of the circumstances of analysis, including whether there
was a "compelling need for official action and no time to secure a
warrant," incorrectly applies this Court's decisions in McNeely and
Mitchell and reaches a result that contravenes the Fourth Amendment
and conflicts with decisions of other state and federal courts.

Whether the Fourth Amendment always permits a warrantless blood draw without consideration of the totality of the circumstances