Taking of Hair Sample Not a ‘Search’

A police officer who was forced to provide a hair sample when he was suspected of drug use may not sue for alleged violations of his Fourth Amendment rights.
In its eight-page unpublished decision in Coddington v. Evanko, the 3rd Circuit refused to carve out any exceptions to its 1982 decision in In re Grand Jury Proceedings (Appeal of Mills), which held that hair samples are “more akin to fingerprinting and voice and handwriting exemplars, which have been held outside the ambit of Fourth Amendment protection.”


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