Maryland v. King Case Brief

Facts of the case

The Maryland DNA Collection Act (MDCA) allows state and local law enforcement officers to collect DNA samples from individuals who are arrested for a crime of violence, an attempted crime of violence, burglary, or attempted burglary. Alonzo Jay King, Jr. was arrested on first and second degree assault charges. While under arrest, but prior to conviction, King’s DNA was collected and logged in Maryland’s DNA database. That database matched King’s DNA to a DNA sample from an unsolved rape case. This sample was the only evidence linking King to the rape. The trial judge denied King’s motion to suppress the DNA evidence and he was convicted of first-degree rape and sentenced to life in prison.King appealed the conviction, arguing that the MDCA was an unconstitutional infringement of his Fourth Amendment privilege against warrantless searches. The Court of Appeals of Maryland reversed, holding that the MDCA was unconstitutional. The court held that King’s expectation of privacy was greater than Maryland’s interest in using the DNA for identification purposes.

CONCLUSION

The Supreme Court determined that taking and analyzing a cheek swab of defendant’s DNA was, like fingerprinting and photographing, a legitimate police booking procedure that was reasonable under the Fourth Amendment because, inter alia, (1) the legitimate government interest served by the Act was the need for law enforcement officers in a safe and accurate way to process and identify the persons and possessions they must take into custody, (2) DNA identification of arrestees, of the type approved by the Act, was no more than an extension of methods of identification long used in dealing with persons under arrest, and (3) regarding defendant’s legitimate expectations of privacy, the intrusion of a cheek swab to obtain a DNA sample was a minimal one. The Supreme Court reversed the judgment of the Court of Appeals of Maryland

  • Advocates: Katherine Winfree for the petitioner Michael R. Dreeben Deputy Solicitor General, Department of Justice, for the United States as amicus curiae, supporting the petitioner Kannon K. Shanmugam for the respondent
  • Petitioner: Maryland
  • Respondent: Alonzo Jay King, Jr.
  • DECIDED BY:Roberts Court
  • Location: Maryland State Police, Forensic Services Division
Citation: 569 US 435 (2013)
Granted: Nov 9, 2012
Argued: Feb 26, 2013
Decided: Jun 3, 2013
Maryland v. King Case Brief