Roger Canelas was convicted of driving under the influence and driving without a valid license after a motorcycle crash. The evidence showed that he had alcohol in his system, smelled of alcohol, appeared dazed, and told officers that he did not remember driving. He challenged the sufficiency of the evidence and the denial of his motion to suppress the blood-test results, arguing that the officer lacked probable cause and had not arrested him before reading the implied-consent notice. The Georgia Court of Appeals held that the combined evidence supported the DUI convictions and established probable cause for the arrest. The court also held that the officer’s verbal statement at the hospital restrained Canelas’s liberty sufficiently to constitute an arrest before the blood draw. The evidence was insufficient, however, to support the conviction for driving without a valid license because the officer’s computer-based recollection did not establish the required motorcycle qualification. The court affirmed the DUI judgment, reversed the license conviction, vacated the sentence, and remanded for resentencing.