Raynor v. State
201 Md. App. 209
Md. Ct. Spec. App.2011Background
- Appellant Glenn Raynor was convicted by a circuit court jury of multiple degrees of rape, assault, burglary, sexual offenses, and property destruction.
- DNA evidence was obtained from swabs of a chair at the police barracks where Raynor had sat, without a warrant or his knowledge, and was later compared to DNA from the crime scene.
- The suppression court held Raynor had no reasonable privacy expectation in the chair or the skin cells left on it, so the chair swab was admissible.
- DNA from the chair matched DNA from the pillow case and patio at the scene, and additional DNA from Raynor's cheek also matched the crime scene samples.
- The victim provided a detailed account of how she concluded Raynor was the attacker years after the crime, and she testified about numerous leads and emails to the police.
- Raynor challenged a late disclosure of emails between the victim and police; the court found the disclosure was untimely but not a basis for mistrial, and sustained other remedies.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| DNA from chair suppression | Raynor inquires warrantless chair DNA violates Fourth Amendment | State's use of chair DNA is identification-like; no privacy interest breached | No reasonable expectation of privacy; admissible as identification DNA |
| Mistrial for undisclosed emails | State violated discovery; emails should have been disclosed before trial | Disclosure was incomplete and delayed; mistrial warranted | No abuse of discretion; discovery remedy short of mistrial appropriate |
| Brady/undisclosed emails | Undisclosed emails could be Brady material affecting guilt/punishment | Emails were not material; jurors would not have reached different verdict | No substantial probability of different outcome; no Brady violation |
Key Cases Cited
- Gamble v. State, 78 Md.App. 112 (Md. Ct. App. 1989) (police property search on own property requires no warrant)
- Williamson v. State, 413 Md. 521 (Md. 2010) (DNA from object in police possession identified like fingerprints; no privacy in identification DNA)
- Raines, 383 Md. 1 (Md. 2004) (DNA collection for identification; discusses privacy limits and database use)
- Hayes v. Florida, 470 U.S. 811 (U.S. 1985) (fingerprinting and related procedures do not intrude privacy as an interrogation)
- Dionisio, 410 U.S. 1 (U.S. 1973) (fingerprint-like evidence involves identification without intruding on private life)
- Wilson v. State, 363 Md. 333 (Md. 2001) (Brady standard uses reasonable probability of different outcome for favorable evidence)
- Yearby v. State, 414 Md. 708 (Md. 2010) (State’s Brady obligations and discovery duties clarified post-rule revision)