A grand jury subpoena was used to get defendant’s palm prints while he was in prison in 2004 to see whether he was connected to a 1997 murder. The grand jury subpoena did not violate the Fourth Amendment or the state constitution. People v. Boston, 2016 IL 118661, 2016 Ill. LEXIS 270 (Feb. 26, 2016).
Defendant’s vehicle was seized within the meaning of the statute and the common meaning of the word. It is not limited, as with the state’s argument, to a seizure with the intent to forfeit. State v. Benally, 2016 N.M. LEXIS 40 (Feb. 25, 2016).