State v. Grant
944 A.2d 947, 2008 Conn. LEXIS 135, 286 Conn. 499 (2008)
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Rule of Law:
A search warrant authorizing the seizure of a routine blood sample satisfies the requirements of the Fourth Amendment when it is supported by probable cause. The mere possibility of an innocent explanation for the evidence connecting a suspect to a crime does not defeat a finding of probable cause.
Facts:
- On July 16, 1973, Concetta Serra was stabbed to death in a New Haven parking garage.
- Police found Serra's body and her father's Buick, which she had been driving, abandoned in the garage.
- Investigators found blood at the crime scene—on the car, in a trail, and on a handkerchief—that was determined to be Type O. The victim's blood was Type A.
- A fingerprint was recovered from a tissue box inside the Buick. Years later, experts determined the fingerprint was left on the box before blood was deposited on it.
- In 1997, using an automated identification system, investigators matched the fingerprint to Edward R. Grant's left thumbprint.
- When questioned by investigators, Grant stated he had Type O blood but could not explain how his fingerprint was on the tissue box, citing memory problems from an old head injury.
- At the time of the murder, Grant worked as a vehicle painter and occasionally traveled to New Haven for business as an insurance adjuster.
Procedural Posture:
- Investigators submitted an affidavit and application for a search warrant for a sample of Edward R. Grant's blood, which a judge granted.
- Following his arrest, the State of Connecticut charged Grant with murder.
- In the trial court, Grant filed a pretrial motion to suppress all evidence derived from the blood sample, arguing the warrant was issued without probable cause.
- The trial court held a hearing and denied the motion to suppress.
- Following a trial, a jury convicted Grant of murder, and the court rendered judgment accordingly.
- Grant (appellant) appealed the judgment directly to the Supreme Court of Connecticut, with the State (appellee) responding.
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Issue:
Does a search warrant to obtain a blood sample violate the Fourth Amendment's probable cause requirement when the primary evidence connecting the suspect to a decades-old murder is a fingerprint on a movable object found inside the victim's car?
Opinions:
Majority - Rogers, C. J.
No, the search warrant does not violate the Fourth Amendment's probable cause requirement. A warrant for a routine blood sample is constitutionally valid if supported by probable cause, and the evidence presented was sufficient to establish that standard. The court first clarified that the heightened 'clear indication' test from Schmerber v. California applies to warrantless searches, not to a routine, medically supervised blood draw authorized by a warrant, for which probable cause is the correct standard. Applying that standard, the court found the affidavit established a fair probability that Grant was the perpetrator. The presence of Type O blood at the scene, which did not belong to the victim (Type A), created a reasonable inference that it belonged to the killer. Grant's fingerprint on the tissue box, combined with his admission of having Type O blood and his inability to provide an innocent explanation, sufficiently connected him to the crime to establish probable cause. The court reasoned that the mere possibility of an innocent explanation for the fingerprint—such as touching the box in a store or during his work as an insurance adjuster—does not negate probable cause, which requires a practical, nontechnical assessment of probabilities, not proof beyond a reasonable doubt.
Analysis:
This decision clarifies that the standard Fourth Amendment probable cause analysis, rather than a heightened evidentiary standard, applies to search warrants for minimally intrusive bodily seizures like routine blood draws. The case is also significant for its application of probable cause in a 'cold case' where the key evidence connecting the suspect is a fingerprint on a readily movable object. It establishes that while the defense may posit innocent explanations for such evidence, these possibilities do not automatically defeat probable cause so long as the totality of the circumstances provides a substantial basis for believing the suspect is connected to the crime. This strengthens the hand of law enforcement in using modern forensic technology to solve old cases based on circumstantial evidence.
