On December 9, 2010, the Massachusetts Supreme Judicial Court ruled in Commonwealth v. Jerry Dixon that prosecutors can indict "John Doe" genetic profiles in rape cases, even without knowing the suspect's name. Specifically, the decision allows prosecutors to indict a suspect's genetic profile so that the state will not be barred by statutes of limitations after apprehending a suspect. Dixon's then-anonymous DNA profile was indicted in 2006 for rapes that occurred in 1991 the statute of limitations for those charges was 15 years. Dixon was identified in 2007 after being required to submit a DNA sample when he was convicted on separate motor vehicle charges. The California Supreme Court had previously authorized similar DNA warrants for unknown suspects in January 2010.