Court finds a reasonable person would believe he was under arrest if officer verbally tells him of arrest

The central question in this license-suspension case was whether a driver had been arrested for DUI before or after being informed of his implied-consent rights.  The driver argued he was not under arrest when the implied-consent notice was read, as he had not been handcuffed at the time.  The Court rejected this argument and affirmed the license suspension.  Given the officer’s testimony that he had verbally informed the driver he was under arrest before the implied-consent notice was read, the Court concluded a reasonable person would believe he was under arrest at that time.