In re the Welfare of M.L.M.
813 N.W.2d 26
Minn.2012Background
- M.L.M., a juvenile, was petitioned for felony possession of burglary tools and later adjudicated delinquent on gross misdemeanor theft over $500 arising from the same incident after a plea bargain that dismissed the felony and two other misdemeanors.
- As part of probation, M.L.M. was ordered to submit to random urinalyses and counseling; the court ordered DNA collection under Minn.Stat. § 609.117, subd. 1(2), stayed for briefing on constitutionality.
- Section 609.117(1)(2) requires DNA collection for juveniles adjudicated delinquent for offenses arising from the same circumstances as a felony petition, with results stored in a state database for identification.
- DNA is analyzed to create a profile used solely for criminal identification; the profile is stored in CODIS with access limited to law enforcement.
- This case tests whether the DNA collection constitutes an unreasonable search under the Fourth Amendment and Article I, Section 10 of the Minnesota Constitution, and whether it violates equal protection.
- The supreme court applied the Knights-Samson totality-of-the-circumstances framework, balancing privacy intrusion against legitimate governmental interests.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is DNA collection under § 609.117(1)(2) an unreasonable search? | M.L.M. argues the collection intrudes on bodily integrity and identity without probable cause. | State contends reduced privacy for a juvenile delinquent and strong governmental interests justify collection. | Not an unreasonable search. |
| Does § 609.117(1)(2) violate equal protection? | Juveniles adjudicated delinquent with a dismissed felony petition are treated differently from those not petitioned for felony. | Different factual situations mean no equal protection violation; the statute targets a distinct class. | No equal protection violation. |
Key Cases Cited
- United States v. Knights, 534 U.S. 112 (2001) (totality-of-the-circumstances balancing governs reasonableness of searches)
- Samson v. California, 547 U.S. 843 (2006) (probation/parole searches analyzed under Knights framework)
- State v. Bartylla, 755 N.W.2d 8 (Minn. 2008) (DNA collection for felons not unconstitutional under Fourth/Mourning constitutional standards)
- State v. Johnson, 813 N.W.2d 1 (Minn. 2012) (applies Knights-Samson to 609.117(1)(1); not unconstitutional)
- Skinner v. Ry. Labor Executives’ Ass’n, 489 U.S. 602 (1989) (biological sample collection constitutes a search)