State ex rel. DeChristopher v. Gaujot (Signed Opinion)
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The Supreme Court granted a writ of prohibition sought by the prosecuting attorney of Monongalia County to prohibit the circuit court from enforcing its order suppressing Cesar Felix's statement to Morgantown police and certain DNA evidence, holding that the circuit court committed clear legal error.
Cesar Felix worked at a restaurant where a woman claimed that she was sexually assaulted upon leaving. When police interviewed him, Defendant denied any involvement in the crime and consented to a DNA search by cheek swab. The DNA evidence linked Felix to the crime, and he was subsequently charged with two counts of sexual assault. Defendant filed a motion to suppress his statement and the DNA evidence, claiming that he was not given Miranda warnings or advised of his right to refuse his consent to the DNA search. The circuit court granted the motion. The Supreme Court reversed, holding (1) Defendant was not in custody when he gave his statement, and therefore, no Miranda warnings were required; (2) Defendant's Fifth Amendment privilege against self-incrimination and due process rights were not violated; and (3) Defendant's Fourth Amendment protection against unreasonable searches was not violated.
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