State of Arizona v. Ian Mitcham

Summary

The court held that police conducted an unreasonable Fourth Amendment search when, years after a DUI blood draw authorized only to measure alcohol or drug content, they extracted Mitcham’s DNA profile from a retained blood vial without a warrant. Nevertheless, suppression was unwarranted because the State proved by a preponderance of the evidence that Mitcham’s DNA profile would inevitably have been obtained through an independent statutory process following his later felony convictions. The court vacated the court of appeals’ opinion, reversed the trial court’s suppression order, and remanded for further proceedings.