Law360 (October 5, 2026, 1:10 PM EDT) -- The U.S. Supreme Court on Monday declined to hear a challenge to a John Doe warrant and the warrantless collection and DNA testing of trash items used to convict a man in 2024 for the rape of a Penn State student in 1995.

The denial of certiorari leaves intact a Pennsylvania Superior Court ruling last year that affirmed Scott Williams' sentence and conviction.

The state appellate court's unanimous opinion said that when investigators had no viable leads on who had beaten and raped a student only identified publicly as T.L., a detective used material from the crime scene to generate a DNA profile for the unknown assailant and file a John Doe complaint and warrant in 2000, shortly before the statute of limitations on the charges would have expired.

Years later, thanks to technological advances that make it possible to locate relatives of suspects via publicly available DNA data, investigators were able to identify the mother of the rapist.

Using that information, they identified Williams as their suspect, collecting his DNA in 2021 from trash he had discarded and matching it with the profile of their suspect based on the earlier DNA profile. Prosecutors charged Williams that same year, according to court records.

While the panel said there was "scant" precedent in Pennsylvania regarding such John Doe warrants, they said the 2006 Pennsylvania Supreme Court decision in Commonwealth v. Laventure showed that in certain circumstances, the warrants could work. A warrant needs to "set forth reasonably specific identification characteristics of an unknown suspect," the judges said, opining that in this case, that burden was met.

Writing for the panel, retired Judge Correale Stevens, who was specially assigned, said "an arrest warrant setting forth a DNA profile satisfies both the particularity requirement of the Fourth Amendment as well as Pennsylvania's constitutional requirement that arrest warrants describe the person to be seized 'as nearly as may be.'"

A DNA warrant doesn't allow "capricious arrests," the panel concluded, noting "a John Doe DNA warrant identifies the perpetrator using a genetic profile with incredible precision."

Though Williams had argued the John Doe complaint and warrant were too nonspecific and "merely referenced six genetic loci at which the DNA profile was developed" without a full profile, the court was unbothered.

Williams petitioned the U.S. Supreme Court in May, arguing that John Doe warrants and the warrantless search and seizure of his trash violated the Fourth Amendment.

"Neither the text and history of the Fourth Amendment nor Supreme Court case law support finding that the Fourth Amendment authorizes law enforcement to not only issue a John Doe arrest warrant (which applies to every human on the planet), but also to warrantlessly seize and extract DNA and create a profile so long as an item with DNA was located outside a persons' home," he argued in his petition for certiorari. "This dangerous 'Brave New World' is no longer the world of science fiction."

On Monday, the high court denied his petition without a written opinion.

An attorney for Williams did not immediately respond to a request for comment Monday.

Williams is represented by Barbara Zemlock, Brian Perry, Heidi Freese, and J. Andrew Salemme of Tucker Arensberg PC.

Counsel information for the government was not available.

The case is Scott R. Williams v. Commonwealth of Pennsylvania, case number 25-1277, in the Supreme Court of the United States.

--Additional reporting by Elizabeth Daley. Editing by Alex Hubbard.

For a reprint of this article, please contact reprints@law360.com.