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DNA

Maryland v. King

Oral argument: 
February 26, 2013
Court below: 
Maryland Court of Appeals

Maryland police arrested Alonzo Jay King, Jr., in 2009 for first- and second-degree assault. Under Maryland’s DNA Collection Act (the “DNA Act”), the police were authorized to collect King’s DNA. When the DNA data was added to the state’s database, it matched a prior set of DNA data collected in a separate 2003 rape case that remained unsolved. Using the 2009 DNA match as evidence, a Maryland trial court convicted King of the 2003 rape. The state’s highest court reversed King’s conviction, finding that the DNA evidence was improperly obtained during an unreasonable search. The court deemed the search unreasonable and thus unconstitutional under the Fourth Amendment because King’s right to the expectation of privacy was greater than Maryland’s interest in using his DNA to identify him. Still, the court upheld the constitutionality of the DNA Act overall. How the Supreme Court decides this case will reflect its view on the correct balance between the government’s interest in solving violent crimes using DNA evidence and an individual’s interest in retaining his Fourth Amendment right against warrantless, suspicionless searches.

Questions Presented: 

Does the Fourth Amendment allow the States to collect and analyze DNA from people arrested and charged with serious crimes?

Williams v. Illinois (10-8505)

Oral argument: December 6, 2011

Appealed from: The Supreme Court of Illinois (July 15, 2010)

Petitioner, Sandy Williams, was charged with sexual assault on 22-year-old L.J in 2000. At trial, the prosecution called an expert witness to testify about DNA test results that identified Williams as the assailant. He moved to strike the evidence under the Sixth Amendment’s Confrontation Clause because the testifying witness had not performed the DNA tests. The court denied his motion and convicted Williams of sexual assault, kidnapping, and robbery. He contends that allowing an expert witness to testify regarding forensic reports when the witness did not prepare the reports violates the Confrontation Clause. Williams insists that he must have the opportunity to cross-examine the analysts that prepared the reports, particularly because DNA test results are prone to error or manipulation. Respondent, the State of Illinois, argues that allowing the expert witness to testify does not violate the Confrontation Clause because the witness was applying her own independent analysis and opinions concerning the report.

Skinner v. Switzer (09-9000)

Oral argument: Oct. 13, 2010

Appealed from: United States Court of Appeals for the Fifth Circuit (Feb. 2, 2010)

FEDERAL HABEAS CORPUS, CIVIL RIGHTS, DNA TESTING, CAPITAL MURDER

Florida convicted petitioner Henry Skinner of capital murder and sentenced him to death. Although Skinner admits that he was present at the scene of the murders, he maintains his innocence. Skinner now seeks access to biological evidence for DNA testing, which he claims will prove that he is innocent of the murders. After unsuccessfully filing two habeas corpus claims, Skinner filed a 42 U.S.C. § 1983 claim to attempt to gain access to the evidence. The Fifth Circuit denied Skinner’s motion to stay his execution, but Skinner appealed that decision and the Supreme Court agreed to hear Skinner’s case. The Court must now decide whether a demand for access to biological evidence may be brought under 42 U.S.C. § 1983, or whether the claim falls within the realm of habeas corpus law and was thus improperly filed. The Supreme Court’s decision will not only decide Skinner’s fate, but also clarify the scope and procedure of habeas corpus claims.

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