Maryland v. King
133 S. Ct. 1958
| SCOTUS | 2013Background
- King was arrested in 2009 for first- and second-degree assault and booked at a Maryland facility.
- As part of booking, officers collected a DNA sample via a cheek swab under the Maryland DNA Collection Act.
- DNA obtained was matched to a 2003 unsolved Salisbury rape, leading to new rape charges against King.
- King moved to suppress the DNA match as unconstitutional under the Fourth Amendment; Maryland courts upheld the statute, then Maryland courts convicted King.
- The Maryland Court of Appeals struck down arrestee-DNA collection provisions; the Supreme Court granted certiorari to resolve Fourth Amendment implications.
- The Court held that DNA collection during booking is a legitimate, reasonable police procedure like fingerprinting and photographing.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is a buccal DNA sample from an arrestee a Fourth Amendment search? | King argues the Act violates the Fourth Amendment. | Maryland contends collection is a routine booking procedure and reasonable. | Yes; it is a Fourth Amendment search but reasonable. |
| Is the intrusion of a cheek swab minimal enough to be reasonable without a warrant? | King contends privacy interests outweigh interests in identification. | State asserts minimal intrusion with substantial government interests. | Intrusion is minimal and outweighed by government interests; reasonable. |
| Does CODIS testing and statutory protections adequately limit privacy concerns? | King argues testing may reveal private information and overcollection occurs. | Act limits data use to identification and imposes safeguards. | CODIS safeguards and noncoding loci limit privacy intrusion; still reasonable. |
Key Cases Cited
- Vernonia School Dist. 47J v. Acton, 515 U. S. 646 (1995) (reasonableness balancing in searches with minimal intrusion)
- Samson v. California, 547 U. S. 843 (2006) (reasonableness in custodial contexts; little individualized suspicion needed)
- Illinois v. Gates, 462 U. S. 213 (1983) (probable cause and reasonable searches; totality of circumstances)
- Schmerber v. California, 384 U. S. 757 (1966) (body intrusions and searches; bodily samples subject to Fourth Amendment)
- Florence v. Board of Chosen Freeholders of County of Burlington, 132 S. Ct. 1510 (2012) (station-house searches and reduced privacy expectations)
- Gerstein v. Pugh, 420 U. S. 103 (1975) (probable cause supports arrest and brief detention for administrative steps)
- U.S. v. Robinson, 414 U. S. 218 (1973) (search incident to lawful arrest is valid; no need for suspicion)
- County of Riverside v. McLaughlin, 500 U. S. 44 (1991) (fingerprinting analogous to routine administrative procedures)
- United States v. Osborn, 557 U. S. 52 (2009) (DNA identification as a legitimate law-enforcement tool)