Corbin v. State
428 Md. 488
Md.2012Background
- Corbin, on probation for a DWI, was subjected to mandatory alcohol monitoring including a deep-lung breath test with a straw.
- The straw, containing Corbin’s saliva, was retained by authorities and sent for DNA analysis, linking him to semen found on a homicide victim.
- A second DNA sample from Corbin confirmed the match; the straw DNA was used at trial to convict him of involuntary manslaughter.
- Corbin moved to suppress the DNA evidence, arguing Fourth Amendment violation; the circuit court and Court of Special Appeals denied the motion, upholding a lack of reasonable privacy expectation.
- The Maryland Supreme Court granted certiorari to address (1) privacy rights of probationers in DNA collected under probation monitoring and (2) sufficiency of the circumstantial evidence.
- The majority held that the DNA collection was reasonable under Knights and Samson; it concluded Corbin, as a probationer, has a diminished but not vanished privacy interest, and affirmed the conviction.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is DNA collected from a straw during probation testing governed by the Fourth Amendment? | Corbin; privacy interest exists in DNA on straw. | State; Knights framework supports allowance of testing given probation context. | Yes; Fourth Amendment applies and search deemed reasonable. |
| Does abandonment doctrine apply to DNA on a straw in probation testing? | Corbin abandoned privacy in straw by not reclaiming it. | State; abandonment not controlling due to compelled collection and non-possession by Corbin. | No; abandonment analysis supports admitted DNA evidence. |
| Does Knights/Samson justify a probationer’s reduced privacy interest when DNA is used for a murder investigation unrelated to probation? | Corbin retained meaningful privacy; DNA testing is a separate search with extensive privacy intrusion. | State’s interest in probation supervision and public safety justifies reduced privacy; DNA testing during probation is permissible. | State interests predominate; probationers have diminished privacy sufficient to permit DNA use. |
| Was the circumstantial evidence sufficient to convict Corbin of involuntary manslaughter beyond a reasonable doubt? | Evidence showed he was last with the victim and semen timing supports presence at death. | Circumstantial links are insufficient due to multiple semen sources and plausible innocence. | Yes; rational juror could find presence at death and involuntary manslaughter beyond a reasonable doubt. |
Key Cases Cited
- Williamson v. State, 413 Md. 521 (2010) (abandonment theory for DNA evidence from discarded items)
- Knights, 534 U.S. 112 (2001) (probationer’s diminished privacy under totality of circumstances)
- Samson v. California, 547 U.S. 843 (2006) (parolee searches; extended probationary privacy considerations)
- King v. State, 425 Md. 550 (2012) (DNA collection statute and arrestee privacy; tension with Williamson)
- Venner v. State, 279 Md. 47 (1977) (abandonment of property doctrine for Fourth Amendment purposes)
- Stanberry v. State, 343 Md. 720 (1996) (abandonment as a basis for Fourth Amendment non-protection)
- Raines, 383 Md. 1 (2004) (DNA collection context; privacy expectations for felons)