State v. Police

Summary

The court held that the John Doe arrest warrant did not satisfy the Fourth Amendment's particularity requirement because it relied on vague physical descriptions and mixed partial touch-DNA profiles that were not shown to uniquely identify the perpetrator or to include the defendant. The warrant therefore did not commence prosecution or toll the applicable statute of limitations, and the trial court erred by relying on later DNA reports that were not part of or incorporated into the warrant. The conviction was reversed and the case remanded for dismissal of the information.