The U.S. Supreme Court on Friday declined to hear an appeal from Manuel Arzola, 47, a Chelsea man convicted in 2012 of stabbing another man in the city. By refusing to review the case, the nation’s highest court upheld a Massachusetts court ruling that investigators do not need a warrant to perform DNA testing on evidence that has been lawfully seized.
Among the evidence presented at trial was a bloodstain found on Arzola’s shirt, which police lawfully seized during his arrest. DNA testing of that stain identified the blood as belonging to the victim. The Massachusetts Supreme Judicial Court affirmed Arzola’s conviction last year in a 21-page decision.
In their ruling, the SJC justices rejected contentions raised by Arzola and the American Civil Liberties Union. The defendants had argued that DNA profiles developed by law enforcement—including the profile from Arzola’s seized clothing—disclose sensitive personal information beyond the sex and unique identity of the DNA source.
The Supreme Court’s refusal to take the case left intact the SJC’s decision, which relied on the Supreme Court’s 2013 ruling in Maryland v. King. That decision established that DNA testing is no more invasive than fingerprinting. The standardized testing method examines 16 loci—or allele locations along a DNA strand—to identify the contributor and compare genetic profiles. According to the Court, this testing approach does not reveal genetic predispositions to medical conditions or other private information, contrary to what Arzola had argued on appeal.
Chief Justice Ralph Gants wrote in the 2015 SJC decision:
“Apart from the source’s sex,” he stated, “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.”
The 2010 stabbing occurred after the victim refused Arzola’s request for money or cigarettes. The victim managed to flee to a nearby firehouse and was transported to Massachusetts General Hospital for treatment. He provided a description of his attacker to police, who stopped Arzola nearby based on that description and arrested him on an outstanding warrant.
At the time of his arrest, Arzola had no visible injuries, but police noticed a large blood stain on his shirt and lawfully seized it. A DNA profile developed from the bloodstain was compared to samples from both the victim and Arzola, which had been obtained through a court order. The testing confirmed that the blood belonged to the victim. The victim subsequently identified Arzola as his attacker through a photo array. Arzola is currently serving a seven-year prison sentence for the non-fatal stabbing.
