King v. State
425 Md. 550
| Md. | 2012Background
- Appellant Alonzo J. King, Jr. was arrested in 2009 for first- and second-degree assault; DNA was collected from him under Maryland’s DNA Collection Act § 2-504(3).
- DNA from King matched a 2003 unsolved rape in Salisbury, leading to indictment for rape; a second DNA sample, obtained by warrant, also matched the 2003 rape.
- King was convicted of first-degree rape and sentenced to life, but the assault charges led to the initial DNA collection before conviction.
- The circuit court denied suppression; the court relied on prior Raines precedent upholding arrestee DNA collection as constitutional.
- Maryland’s Act allows DNA collection from arrestees charged with crimes of violence or burglary before conviction; the DNA record is used for identification and later corroboration, with expungement if not convicted.
- The Court of Appeals held the arrestee DNA collection unconstitutional as applied to King, applying the Fourth Amendment totality-of-the-circumstances balancing and suppressing the evidence, remanding for a new trial.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether arrestee DNA collection violates the Fourth Amendment as applied to King | King argues the Act violates privacy and requires individualized suspicion | State contends identification interests and forensic needs justify arrestee sampling | Unconstitutional as applied; suppression warranted |
| Whether the burden-shifting framework used at suppression hearings was correct | King contends the State failed to show a proper basis for warrantless collection | State maintains balancing framework supports reasonableness | Renders unnecessary to decide after ruling on unconstitutionality (moot) |
| Whether the second DNA sample obtained via a warrant was tainted as fruit of the poisonous tree | Since first collection was unlawful, subsequent evidence is tainted | Second sample independently linked to charges via probable cause | Suppressible as fruit of the poisonous tree; case remanded for new trial |
Key Cases Cited
- United States v. Knights, 534 U.S. 112 (2001) (totality-of-the-circumstances balancing for police intrusions)
- Katz v. United States, 389 U.S. 347 (1967) (two-part test for reasonable expectation of privacy)
- Raines v. State, 383 Md. 1 (2004) (DNA collection from felons; severely diminished privacy expectation)
- Williamson v. State, 413 Md. 521 (2010) (DNA from arrestees; identification purpose; balancing test)
- State v. Crs. Pool v. Pool, 621 F.3d 1213 (9th Cir. 2010) (watershed event; arrestee DNA identification vs. investigation)
- United States v. Kriesel, 508 F.3d 941 (9th Cir. 2007) (DNA sampling of convicted felons; identification rationale)
- United States v. Kincade, 379 F.3d 813 (9th Cir. 2004) (DNA sampling; identification analogy debates)
- Haskell v. Harris, 669 F.3d 1049 (9th Cir. 2012) (arrestee DNA collection; privacy vs. identification)