California’s initiated DNA collection act requiring DNA sampling of those charged with serious felonies applies to defendant’s arson arrest. He refused to provide a sample on booking and was convicted of a misdemeanor offense. The California statute is not exactly the same as the Maryland statute in King, but the statute is close enough that King controls. People v. Buza, 2018 Cal. LEXIS 2245 (Apr. 2, 2018).
2255 petitioner couldn’t show that a dog sniff from a common area of an apartment building would have been suppressed at the time of the dog sniff before Jardines. Therefore, a motion to suppress would have been granted. Seay v. United States, 2018 U.S. Dist. LEXIS 55894 (D. Md. Apr. 2, 2018).*