Maryland v. King
567 U.S. 1301
| SCOTUS | 2012Background
- Maryland enacts DNA Collection Act authorizing collection from individuals arrested for certain violent crimes or first-degree burglary.
- Alonzo Jay King, Jr. was arrested in 2009 for first-degree assault; DNA from booking matched a 2003 rape, leading to King’s conviction for first-degree rape among others.
- Maryland Supreme Court of Appeals overturned King’s conviction, holding the DNA collection violated the Fourth Amendment due to privacy interests.
- Maryland seeks a stay of that judgment pending this Court’s certiorari review.
- Standards for issuing a stay require showing probable certiorari, likelihood of reversal, and irreparable harm if stay is denied; the Court weighs these factors.
- The Court finds a reasonable probability of certiorari and reversal, and finds irreparable harm from denying the stay, justifying a stay pending certiorari.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Certiorari probability and likely reversal | Maryland argues split among circuits supports certiorari and reversal. | King contends no certiorari likelihood or reversal. | Yes; substantial probability of certiori and reversal found. |
| Irreparable harm from denial of stay | Continued DNA collection harms public safety and enforcement interests absent stay. | Delay harms litigants and accumulating data undermines privacy concerns. | Ongoing irreparable harm shown; stay granted. |
| Balance of equities and public interest | Staying preserves useful law-enforcement tool and database integrity. | Statutory injunction promotes privacy rights and constitutional restraints. | Equities favor stay to permit certiorari review without unduly harming enforcement. |
Key Cases Cited
- Conkright v. Frommert, 556 U.S. 1401 (2009) (stay standards; irreparable harm emphasis)
- New Motor Vehicle Bd. of Cal. v. Orrin W. Fox Co., 434 U.S. 1345 (1977) (irreparable injury when enjoined against statutory enactments)
- United States v. Mitchell, 652 F.3d 387 (3d Cir. 2011) (split on DNA arrestee statutes; certiorari sought)
- Haskell v. Harris, 669 F.3d 1049 (9th Cir. 2012) (upholding DNA-collection statutes)
- Anderson v. Commonwealth, 274 Va. 469, 650 S.E.2d 702 (2007) (Virginia upholds similar DNA collection statute)