In U.S. v. Pettiford, 295 F. Supp. 2d 552 (D. Md. 2003), the defendant was apprehended after the police responded to the scene of a "road rage" shooting. Id. at 555-57. The police observed Pettiford only minutes after the shooting, in a location only a few blocks from where the incident had occurred, traveling in the direction the shooter reportedly was driving when he left the scene of the crime. Id. at 558. Pettiford matched the physical description of the shooter and was driving a car that matched descriptions of the shooter's car. Id. Also, the front passenger window of Pettiford's car was broken, with glass still falling to the ground, indicating that the damage had occurred recently. Id. Pettiford initially attempted to evade the police, but was quickly apprehended. Id. While questioning Pettiford, the police observed bullet holes in the driver's side door of his car. Id. at 559. Pettiford admitted that he was involved in the "roadrage" incident, but claimed that he was only a victim, not a shooter. Id. at 555, 559. After the police seized his car and towed it away as evidence of the shooting, Pettiford voluntarily accompanied an officer to the police station where he submitted to a GSR test without objection. Id. at 556. Pettiford was then held at the police station for more than five hours before he was placed under arrest for his participation in the shooting. Id. at 555-57. Prior to trial, Pettiford moved to suppress the GSR evidence, arguing that it was collected without a warrant in violation of his Fourth Amendment rights. Id. at 560. In its ruling on Pettiford's motion to suppress, the United States District Court for the District of Maryland first determined that the initial investigative stop of Pettiford was adequately supported by reasonable articulable suspicion, and that Pettiford's subsequent detention and arrest were based upon probable cause; therefore, Pettiford's arrest was legal. Id. at 558, 559. Considering Pettiford's argument that suppression of the GSR evidence was necessary, the Court concluded that Pettiford had consented to the collection of the GSR evidence. Id. at 560. The Court further opined, however, that even had Pettiford not consented, the evidence collected during the warrantless search would be admissible pursuant to the exigent circumstances exception to the warrant requirement. Id. In support of its holding, the Court recounted the information that was known to the police at the time the GSR evidence was collected and concluded that the detective who conducted the search, "had probable cause to believe that the GSR test would yield evidence that Pettiford had discharged a firearm." Id. The Court next noted testimony indicating that GSR evidence remains detectable on a person's hands for only a limited period of time after a shooting, and that it is easily destroyed. Id. at 560-61. The Court opined that delay to obtain a search warrant to conduct the GSR test increases a detainee's "opportunity to destroy the evidence by simply washing his hands." Id. The Court also observed that the GSR test required only the swabbing of Pettiford's hands, which constituted "only a minimal intrusion" upon his privacy. Id. at 561. Based upon its determinations, the Pettiford Court ultimately concluded that exigent circumstances justified the warrantless collection of the GSR evidence and, therefore, the evidence was admissible at Pettiford's trial. Id. at 561.