Whether the police were required to obtain a search warrant before submitting trash items to a forensic lab to extract DNA and create a DNA profile for a criminal investigation

QUESTION PRESENTED FOR REVIEW I. The Fairfax County Police seized trash from in front of Jude Lovchik’s home. The items seized were then submitted to the Virginia Department of Forensic Science to extract DNA from those items and create a DNA profile to compare to an evidentiary sample from an unsolved sexual assault. The police did not obtain a search warrant prior to submitting the trash items to the forensic lab to be tested for DNA. The question presented is whether the police were required to obtain a search warrant before they searched for DNA on the trash items which was used to create a DNA profile to further a criminal investigation. ii LIST OF ALL DIRECTLY