No, he was acting on what he had been allowed to get away with in the past. Wrongly. Implied consent requires medical practicality- such as you are in an accident and they do CPR without knowing if you have a DNR. This was illegal search and seizure, it had nothing to do with his immediate peril. The force is using that to have an excuse for their practices. And I am certain there was never a policy that said that you could rough up someone who was protecting the legal rights of a comotose citizen. The nurse did nothing that justified him touching her in any way, especially in anger. She said no to his illegal demand, period.