Sutton v. Pfister, No. 15-2888 (7th Cir. 2016)
Annotate this CaseSutton has been convicted of violent crimes in multiple separate Illinois prosecutions, including 1991 and 1997 convictions for attempted aggravated criminal sexual assault and aggravated criminal sexual assault. The state concedes that it unlawfully collected a sample of Sutton’s blood during the 1991 prosecution and then used that blood sample in the 1997 prosecution. In his habeas conviction, relating to the 1997 case, the district court granted relief. The Seventh Circuit reversed, citing the inevitable discovery doctrine. Although the court order under which the blood was collected was not supported by probable cause, the blood (and thus the DNA) would inevitably have been produced under a state law that provided legal authority for collecting the sample. The relevant statute stated that persons convicted of certain sexual offenses “shall … be required to submit blood samples and saliva to the Illinois State Police.” (currently codified at 730 ILCS 5/5-4-3).
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