State v. Carlson
845 N.W.2d 827
Minn. Ct. App.2014Background
- July 15, 2006: residential burglary; blood found at scene; items and a 2006 Dodge Charger stolen; blood samples collected and later profiled.
- DNA from blood at the residence matched DNA on a can recovered from the stolen car; a 15-loci DNA profile (extremely rare) was produced.
- June 15, 2009: State filed a John Doe probable-cause complaint within the 3-year statute of limitations, identifying the suspect by the 15-loci DNA profile (not by name).
- February–August 2010: Bureau of Criminal Apprehension matched the profile to Carlson; police interviewed him and later obtained a warrant and a DNA sample that matched.
- January 2012: State filed an amended complaint substituting Carlson’s name; Carlson moved to dismiss arguing the John Doe/DNA description failed to identify him with reasonable certainty and that prosecution was time-barred.
- District court denied dismissal; Carlson was convicted after a stipulated-facts trial and placed on probation. Minnesota Court of Appeals affirmed.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether a John Doe complaint describing the defendant solely by a DNA profile satisfies the Fourth Amendment and Minn. R. Crim. P. 3.02, subd. 1 particularity/"reasonable certainty" requirement | Carlson: DNA profile, unlike a name or physical description, does not describe a person with reasonable certainty for warrant/complaint purposes | State: a unique multi-locus DNA profile is a highly specific identifier that meets constitutional and rule-based particularity and reasonable-certainty requirements | Court: DNA profile (15 loci) meets and exceeds particularity and reasonable-certainty requirements; John Doe complaint was sufficient |
| Whether filing a John Doe DNA complaint within the limitations period preserves the State’s ability to later amend to the defendant’s name without violating the statute of limitations | Carlson: statute requires filing against a named defendant within three years; later naming nullifies limitations protection | State: filing a complaint that identifies the offender with reasonable certainty (here by DNA) commences prosecution within the limitations period; amendment to add name is permissible | Court: John Doe DNA complaint filed within the 3-year period satisfies the statute of limitations; prosecution not time‑barred |
Key Cases Cited
- State v. Dabney, 663 N.W.2d 366 (Wis. Ct. App. 2003) (holds a unique DNA profile can satisfy warrant particularity and "reasonable certainty")
- People v. Robinson, 47 Cal.4th 1104 (Cal. 2010) (endorses DNA-profile John Doe warrants as sufficiently particular)
- Commonwealth v. Dixon, 938 N.E.2d 878 (Mass. 2010) (describes DNA profile as an indelible identifier sufficient for charging)
- People v. Martinez, 52 A.D.3d 68 (N.Y. App. Div. 2008) (upholds John Doe DNA complaint as timely and particular)
- State v. Belt, 179 P.3d 443 (Kan. 2008) (rejects inadequate DNA description where the loci were few/common; recognizes in principle DNA profiles can meet requirements)
- State v. Burdick, 395 S.W.3d 120 (Tenn. 2012) (supports use of unique DNA profiles to identify unknown suspects in complaints)