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645 P.2d 1390

Pyle v. State

Court of Criminal Appeals of Oklahoma · decided 1982-04-22

Key passage — most relied on by later courts

“Despite the State's assertion of necessity, we hold that it is not only unnecessary, but it is improper procedure to require an accused to provide physical samples for testing by the State prior to the State's testing of specimens from the body of the victim and the scene of the crime. . . . However, we see the issue as being whether the State has presented sufficient evidence of the probative value of such tests in the prosecution of the case. If the State can show the probative value of the requested tests at an evidentiary hearing, then the defendant may be subject to submitting to the extractions in a reasonable manner, of similar samples from his own body.”

quoted by 2 later decisions, including FREDERICK v. STATE, FREDERICK v. STATE

Relies on Hughes v. State

Good law ✅— No negative treatment on recordhow we know

Decided 1982-04-22

How this case has been cited

Cited by 7 later decisions — most recently May 2017

5 state decisions

301982199020002010decided

Later decisions citing this case, by decade. The current decade is in progress, and our corpus holds fewer opinions from the most recent years, so the latest bars are undercounted — not a real decline.

View the full empirical analysis of this case →

BRETT, Presiding Judge,

¶1specially concurring in results:

¶2In Cole v. Parr, 595 P.2d 1349 (Okl.Cr.1979), this Court considered the balance to be struck between the State’s need to analyze speciments from those accused of criminal conduct and the Fourth Amendment’s protection of personal privacy and dignity against unwarranted intrusion by the State. We held that justice could best be served if the State was first required to obtain and analyze samples taken from the body of the victim and the scene of the crime. Aftér this is accomplished, the State must demonstrate to a magistrate at an evidentiary hearing that probable cause exists to believe that there is a rational connection joining the samples within the possession of the State and the specimens sought of the defendant. Only then did we consider probable cause to be sufficiently established to override the Fourth Amendment’s protections.

¶3In the instant case the State failed to meet the guidelines established in Cole. The decision of Cole v. Parr, supra, however, was not rendered until after the specimens of this defendant had been seized and the appellant failed to come to this Court seeking a writ of prohibition against the State’s procedure as did the defendant Cole. In light of this and the other overwhelming evidence against the appellant, I concur in the majority’s decision not to reverse on this basis but dissent to the abandonment of this Court’s unanimous holding in Cole v. Parr, supra.

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