State v. Police
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The Supreme Court reversed the judgment of the trial court accepting Defendant's plea of nolo contendere to robbery in the first degree and assault in the first degree and sentencing Defendant to an aggregate sentence of ten years' imprisonment, holding that a John Doe arrest warrant was invalid and could not commence prosecution for purposes of satisfying the statute of limitations.
On appeal, Defendant argued that the John Doe arrest warrant that identified the suspect on the basis of a general physical description and several mixed partial DNA profiles to which the suspect may not have been a contributor and that did not state the probability that a random person would match any of the profiles did not satisfy the particularity requirement of the Fourth Amendment for purposes of commencing a prosecution within the applicable statute of limitations. The Supreme Court agreed, holding that, to satisfy the Fourth Amendment's particularity requirement, the affidavit accompanying a John Doe DNA arrest warrant application must contain information assuring the judicial authority issuing the warrant that the DNA profile identifies the person responsible for the crime on the basis of his or her unique DNA profile and should include information as to the statistical rarity of that DNA profile.
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