Can Grand Jury Subpoena to Appear In a Lineup and Submit to Fingerprinting and the Taking of Hair Samples ?

In In re May 1991 Will County Grand Jury, the issue before the supreme court was whether a grand jury could subpoena defendants to appear in a lineup and submit to fingerprinting and the taking of hair samples. Will County, 152 Ill. 2d at 385-86. The court held that section 6 recognizes a zone of personal privacy" that is stated broadly and without restrictions. Will County, 152 Ill. 2d at 391. The court held that once a right to privacy is established, the court must determine whether a search and seizure is reasonable. Will County, 152 Ill. 2d at 392. In establishing the reasonableness of a grand jury subpoena for physical evidence of a nonintrusive nature, the State must establish relevance and make a showing of "individualized suspicion." Will County, 152 Ill. 2d at 393.