Supreme Court carefully analyzed Schmerber and other opinions. The court concluded that its decision was in accord with the view of a majority of the courts that had considered the issue. The court also considered the burden on law enforcement of obtaining a warrant: Further, requiring law enforcement to consider other factors places an unreasonable burden on law enforcement. For instance, though the officer may be familiar with the area in which the accident occurred, the officer has no control over how long it would take to travel to a judge or the judge's availability. The officer 335 (1992) (relying mainly on the Oregon Constitution in declining to hold that blood-alcohol dissipation creates a per se exigency); Bristol v. Commonwealth, 272 Va. 568, 636 S.E.2d 460, 464 (2006) (<HOLDING>). 11 . 90 P.3d 156. 12 . Schmerber, 384 U.S. at
holding that the dissipation of alcohol from a persons blood stream constitutes a sufficient exigency to justify a warrantless blood draw holding that blood alcohol dissipation was not sufficient by itself to create an exigent circumstances exception to virginia statutory requirement that the driver be arrested within three hours of the offense holding that exigent circumstances were created by dissipation of bloodalcohol content in time needed to obtain a warrant holding that in drunkdriving investigations the natural dissipation of alcohol in the bloodstream does not constitute an exigency in every case sufficient to justify conducting a blood test without a warrant recognizing exigent circumstance exception to warrant requirement