Douglas A. Guilmette v. State of Indiana
14 N.E.3d 38
| Ind. | 2014Background
- Guilmette was arrested on theft charges after police confronted him with surveillance video.
- Police seized Guilmette’s clothing, including his shoes, during booking under standard procedures.
- A blood-like substance on the shoe laces was tested and contained Piechocki’s DNA, linking to the murder victim.
- Guilmette was charged with murder, theft, and habitual offender status; he moved to suppress the shoe DNA evidence.
- The trial court admitted the DNA evidence; Guilmette appealed, and the Court of Appeals affirmed in part and reversed in part; the Indiana Supreme Court granted transfer.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether DNA testing of shoe evidence requires a separate warrant. | Guilmette claims testing was not a valid search incident to arrest. | State argues testing is permissible as a search incident to a lawful arrest. | DNA testing admissible; no additional warrant required. |
| Whether admission of shoe DNA evidence violates Article 1, Section 11 of the Indiana Constitution. | Guilmette asserts testing targeting a different crime exceeded the scope of the arrest. | State maintains testing of seized items remains permissible regardless of the crime tested for. | Admission proper; testing fell within permissible search incident to arrest. |
Key Cases Cited
- U.S. v. Edwards, 415 U.S. 800 (U.S. 1974) (tests on seized clothing may be admitted after arrest)
- Farrie v. State, 255 Ind. 681 (Ind. 1971) (search incident to arrest lawful regardless of what it reveals)
- Litchfield v. State, 824 N.E.2d 356 (Ind. 2005) (totality of circumstances for reasonableness under Article 1, §11)
- Sears v. State, 668 N.E.2d 662 (Ind. 1996) (search without warrant incident to valid arrest permissible)
- Akins v. State, 429 N.E.2d 232 (Ind. 1981) (clothing may be seized and examined after lawful arrest)