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delay between the defendant’s arrest and the reading of the implied consent notice did not require suppression of the chemical test results when the arresting officer was dealing with a second intoxicated driver and investigating the accident scene); Mason v. State, 177 Ga.App. 184, 186(2), 3380 S.E.2d 706 (1985) (holding that a 20 to 30 minute delay was warranted when the arresting officer was investigating the accident scene and dealing with the hazard created by the wrecked vehicle).” Distinguishes cases where officer had no basis for delay: “ State v. Lamb, 217 Ga.App. 290, 291-292, 456 S.E.2d 769 (1995) (the officer ‘preferred’ to read the implied consent warning in the presence of a witness, resulting in the defendant’s transport to the police station and an unlawful 30-minute delay); Vandiver v. State, 207 Ga.App. 836, 837-838(1), 429 S.E.2d 318 (1993) (the department’s ‘standard practice’ was to wait until the defendant was transported to the jail before delivering the notification, resulting in an inexcusable delay and the reversal of the conviction); Clapsaddle v. State, 208 Ga.App. 840, 841-842(1), 432 S.E.2d 262 (1993) (the accused was not given his implied consent rights until after he was transported to the jail, for no apparent reason). Likewise, the arresting officer in Carthon v. State [March 23, 2001, see below] did not deliver the notification until after he transported Carthon to the hospital for testing, 45-minutes to one hour after her arrest, without even notifying her about the reason for the hospital trip. 248 Ga.App. 738, 740-741, 548 S.E.2d 649 (2001), disapproved on other grounds by Handschuh v. State, 270 Ga.App. 676, 681, 607 S.E.2d 899 (2004). This Court held that, in that situation, Carthon’s rights under OCGA § 40-6-392(a)(4) were violated. Id.” Hough v. State, 279 Ga. 711, 620 S.E.2d 380 (October 3, 2005). “[N]othing in OCGA § 40-5-55 requires a DUI suspect to be arrested in order to trigger his or her implied consent to testing following a traffic accident resulting in serious injuries or fatalities.” Hough’s conviction, following a serious injury accident, is therefore upheld. However, companion case defendant Handschuh’s conviction was properly reversed by the Court of Appeals, because Handschuh’s accident did not meet the strict definition of a “serious injury accident” found in OCGA § 40-5-55(c). “[A] suspect who is not involved in a traffic accident resulting in serious injuries or fatalities must be under arrest before implied consent rights are read to him.” “Here, there is no question that Handschuh was not arrested until six days after the day he was read his implied consent rights. Thus, the reading of Handschuh’s implied consent rights was in no way contemporaneous to his arrest for DUI. As such, we must agree with the Court of Appeals that the trial court erred by denying Handschuh’s motion to suppress. However, we must disapprove of the Court of Appeals decision to the extent that it, in turn, disapproves of its decision in Hough v. State and other decisions which are not inconsistent with our rulings today.” Accord, Ellis v. State , 275 Ga.App. 881, 622 S.E.2d 89 (October 17, 2005); Hannah v. State , 280 Ga.App. 230, 633 S.E.2d 800 (June 30, 2006) (no arrest required where defendant involved in serious injury accident, officer has probable cause to believe defendant may have committed DUI). Evans v. State, 274 Ga.App. 845, 619 S.E.2d 341 (July 29, 2005). “[A]n arrest does not necessarily have to precede the reading of the implied consent notice. Rather, the controlling rule of law is that ‘the implied consent warning must be given at the time of the arrest, or at a time as close in proximity to the instant of arrest as the circumstances of the individual case might warrant.’ (Citation and punctuation omitted.) Crawford v. State, 246 Ga.App. 344, 345(1) (540 S.E.2d 300) (2000). In this case, the police officer testified unequivocally that he arrested Evans, and issued him the DUI citation, in the hospital. Even if we assume for the sake of argument that this arrest formally occurred shortly after the reading of the implied consent warning, when the officer issued the citation to Evans, the warning was sufficiently close in proximity to the instant of arrest to be valid. Id. (implied consent warning given shortly before formal arrest was timely). Compare Handschuh v. State, 270 Ga.App. 676, 678(1) (607 S.E.2d 899) (2004) [ affirmed, 279 Ga. 711, 620 S.E.2d 380 (October 3, 2005) ] (implied consent notice given six days before arrest not timely). The trial court therefore did not err in denying Evans’ motion to suppress.” Conflicts with Supreme Court’s Hough decision (October 3, 2005), above. Cain v. State, 274 Ga.App. 533, 617 S.E.2d 567 (July 6, 2005). “Here, the Cains’ drunken and obstreperous behavior, much of which was recorded on the patrol car’s video camera, led the officer to believe that he should delay the reading of the implied consent warning until his return to the sheriff’s department. There was evidence to support the trial court’s determination that this delay was justified by the circumstances, and that an earlier reading of the warning would have been of no benefit to Cain. See Townsend v. State, 236 Ga.App. 530, 532(1)(b) (511 S.E.2d 587) (1999). The trial court thus did not err when it denied the motion to suppress. Id .” Compare Austell (March 23, 2007), above (affirming trial court’s opposite finding under similar circumstances). State v. Bass, 273 Ga.App. 540, 615 S.E.2d 589 (June 6, 2005). Implied consent blood test results were properly excluded by trial court because defendant was not under arrest at time blood was drawn, even though officer read implied consent warning to defendant while he was unconscious at hospital. Provision in OCGA § 40-5-55(b) providing that unconscious persons are deemed not to have withdrawn their implied consent does not require a different result, because consent is not