The nation’s highest court declined to review the appeal of a Chelsea man convicted in part through DNA evidence, letting stand a Massachusetts court ruling that a warrant is not necessary for investigators to perform DNA testing of lawfully seized evidence.
The Supreme Court of the United States on Friday denied a petition for review filed on behalf of Manuel Arzola, 47, who was convicted in 2012 of stabbing another man in Chelsea. Among the evidence at trial was a bloodstain on Arzola’s shirt, which was lawfully seized at the time of his arrest; that stain was subjected to DNA testing that revealed the blood had come from the victim.
The Massachusetts Supreme Judicial Court last year affirmed Arzola’s conviction. In a 21-page decision, the SJC justices rejected arguments made by Arzola and the American Civil Liberties Union that DNA profiles used by members of law enforcement – such as the profile developed from Arzola’s seized clothing – reveal private information beyond the sex and unique identity of the person who provided the DNA sample.
By declining to review Arzola’s appeal, the Supreme Court left in place the SJC’s decision that cited the Supreme Court’s 2013 decision finding DNA testing no more invasive than fingerprinting. In that case, Maryland v. King, the Supreme Court ruled that the standardized testing method used by law enforcement examines only the identity of the contributor by looking at 16 loci – or allele locations along a strand of DNA – in order to compare genetic profiles and determine identity. Used this way, the testing method does not reveal genetic dispositions toward medical conditions or other private information – contrary to Arzola’s claims on appeal.
“Apart from the source’s sex,” Chief Justice Ralph Gants wrote in the 2015 SJC decision, “the DNA analysis of the unknown sample taken from the defendant’s lawfully seized shirt revealed nothing more than the identity of the source, which is what an analysis of latent fingerprints would have revealed (albeit with less accuracy) had they been found on the clothing …. Although we recognize that the science of DNA analysis may evolve and enable DNA profiling to uncover from these loci information more personal than the identity and sex of its source, the loci tested in this case ‘are not at present revealing information beyond identification’ and sex.”
Arzola is currently serving a seven-year prison term for the non-fatal stabbing of a man in Chelsea after the victim denied his request for money or cigarettes in 2010. The victim fled to a nearby firehouse and was rushed to Massachusetts General Hospital for treatment. He was able to provide a description of his attacker, and, based on that description, responding Chelsea Police stopped Arzola nearby and arrested him on an outstanding warrant.
Though he had no visible injuries at the time of his arrest, police observed a large blood stain on Arzola’s shirt and lawfully seized it. A DNA profile developed from the bloodstain was compared to a sample provided by the victim and to a sample obtained from Arzola through a court order; the scientific testing proved that the blood belonged to the victim. In addition, the victim later identified Arzola as his attacker in a photo array.