State v. BrownAnnotate this Case
The Supreme Court reversed the decision of the court of appeals affirming Defendant's conviction, holding that a body cavity search performed by forcing Defendant to be strapped down and sedated in order to undergo an invasive anoscopy against his will in the presence of nonmedical personnel was unreasonable under the Fourth Amendment.
After Defendant was strapped down and sedated he was forced against his will to undergo an anoscopy. During the procedure, the doctor located a plastic baggie containing cocaine in Defendant's body cavity. The State charged Defendant with one count of fifth-degree possession of a controlled substance. Defendant moved to suppress evidence of the drugs, arguing that the search, even though conducted pursuant to a valid search warrant, was unreasonable. The district court denied the motion, and Defendant was convicted. The court of appeals affirmed, concluding that the anoscopy was a reasonable search. The Supreme Court reversed, holding that the extreme intrusion of Defendant's dignitary rights by the coerced anoscopy outweighed the State's need to retrieve relevant evidence of drug possession, and therefore, the evidence retrieved from the search must be suppressed.