State v. Johnson
813 N.W.2d 1
Minn.2012Background
- Johnson was charged with felony domestic assault by strangulation and misdemeanor fifth-degree assault arising from the same incident.
- He pled to a lesser misdemeanor, with the felony dismissed as part of a plea agreement.
- The district court ordered Johnson to provide a DNA sample under Minn. Stat. § 609.117, subd. 1(1), stayed pending appeal.
- The issue is whether the DNA collection under § 609.117, subd. 1(1), constitutes an unreasonable search under the Fourth Amendment and Minnesota Constitution.
- Johnson argued the statute is unconstitutional as applied to him; the State argued the interests in DNA collection outweigh his privacy expectation.
- The Supreme Court upheld the statute as applied to Johnson, balancing privacy interests and governmental interests.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Is § 609.117,1(1) constitutional as applied? | Johnson argues it is an unreasonable search. | State argues reduced privacy expectation and strong governmental interests justify collection. | Not unconstitutional as applied. |
| Does § 609.117,1(1) violate equal protection? | Johnson contends disparate treatment from misdemeanants without felonies. | State argues not similarly situated. | No equal-protection violation. |
| Do the State’s interests in DNA collection outweigh Johnson's privacy interests? | Johnson's privacy in DNA is high; collection is excessive. | Interests include exoneration, deterrence, identification, and closure. | Interests outweigh privacy; DNA collection reasonable. |
| Is Johnson entitled to relief based on dissenting views of privacy? | Dissent argues statute unconstitutional as applied. | Majority adheres to Knights-Samson approach. | Dissenting views do not control the outcome. |
Key Cases Cited
- United States v. Knights, 534 U.S. 112 (2001) (totality-of-the-circumstances approach to searches in probation context)
- Samson v. California, 547 U.S. 843 (2006) (parolees may be subject to suspicionless searches under totality analysis)
- State v. Bartylla, 755 N.W.2d 8 (Minn. 2008) (upheld DNA collection for felons under Knights-Samson framework)
- Skinner v. Ry. Labor Execs.’ Ass’n, 489 U.S. 602 (1989) (DNA collection implicated privacy interests; profiling scope)