Arizona v. Youngblood

Supreme Court of United States
488 U.S. 51 (1988)

ELI5:

Rule of Law:

The Due Process Clause of the Fourteenth Amendment does not require the state to preserve evidentiary material that is only potentially useful to a criminal defendant unless the defendant can demonstrate that the police acted in bad faith in failing to preserve it.

Facts:

On October 29, 1983, a 10-year-old boy, David L., was abducted from a carnival and sexually assaulted by a middle-aged man.
Following the assault, a physician at Kino Hospital used a 'sexual assault kit' to collect semen samples from the boy’s rectum and mouth, which were then refrigerated by the police.
Police also collected the boy's T-shirt and underwear, which contained semen stains, but this clothing was not refrigerated or otherwise preserved.
Nine days after the attack, the boy identified Larry Youngblood from a photographic lineup.
A police criminologist examined the refrigerated samples from the kit but performed no tests to identify blood group substances.
Over a year later, the criminologist examined the clothing for the first time and found semen stains, but tests on these degraded samples were inconclusive as to the assailant's identity.
Expert testimony at trial indicated that timely tests on the semen samples, had they been properly preserved, might have produced results that could have exonerated Youngblood.

Procedural Posture:

Larry Youngblood was charged in a Pima County, Arizona, trial court with child molestation, sexual assault, and kidnaping.
A jury convicted Youngblood as charged.
Youngblood, as appellant, appealed his conviction to the Arizona Court of Appeals.
The Arizona Court of Appeals reversed the conviction, holding that the state's failure to preserve potentially exonerating evidence violated due process.
The State of Arizona, as appellee, petitioned the Supreme Court of Arizona for review, which was denied.
The State of Arizona, as petitioner, successfully sought a writ of certiorari from the Supreme Court of the United States.

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Issue:

Does the state's failure to preserve potentially useful evidence constitute a denial of due process of law where the defendant cannot show that the police acted in bad faith?

Opinions:

Majority - Chief Justice Rehnquist

No, the state's failure to preserve potentially useful evidence does not constitute a denial of due process of law unless a criminal defendant can show bad faith on the part of the police. The Due Process Clause imposes a different standard for failing to preserve potentially useful evidence than it does for failing to disclose known exculpatory evidence under Brady v. Maryland. While Brady violations do not depend on the good or bad faith of the prosecution, the duty to preserve evidence that is merely potentially useful is not absolute. Requiring a showing of bad faith limits the police's preservation obligation to reasonable bounds and confines it to cases where the police conduct indicates the evidence could have exonerated the defendant. In this case, the police failure to refrigerate the clothing was at worst negligent, and there was no suggestion of bad faith; therefore, there was no due process violation.

Dissenting - Justice Blackmun

Yes, the state's failure to preserve constitutionally material evidence can violate due process regardless of bad faith. The majority misreads precedent like Brady and Trombetta, which focus on the character and materiality of the evidence, not the moral culpability of the prosecutor or police. The Constitution guarantees a fair trial, not just a 'good faith' attempt at one. By allowing potentially exonerating evidence to deteriorate through ineptitude, the state deprived Youngblood of the opportunity to present a full defense, rendering his trial fundamentally unfair. The focus should be on the materiality of the lost evidence and the fairness of the trial, not on the difficult-to-prove state of mind of the police.

Concurring - Justice Stevens

No, there was no due process violation in this specific case, but the majority's creation of a broad bad-faith rule is unnecessary and potentially problematic. In this case, Youngblood was not prejudiced because the trial judge instructed the jury that they could infer the lost evidence would have been unfavorable to the state. The jury's decision to convict despite this instruction suggests the other evidence of guilt was overwhelming, rendering the lost evidence immaterial in the context of the entire record. However, there may be future cases where the loss of evidence is so critical to the defense that it makes a trial fundamentally unfair, even without proof of police bad faith.

Analysis:

This decision establishes the 'bad faith' test, significantly narrowing the state's due process obligation to preserve evidence. It creates a crucial distinction between failing to disclose known exculpatory evidence (the Brady rule, where bad faith is irrelevant) and failing to preserve 'potentially useful' evidence. By requiring defendants to prove the subjective bad faith of the police, the ruling makes it substantially more difficult to succeed on claims of lost or destroyed evidence. This standard protects police from claims based on mere negligence or oversight in evidence handling, but critics argue it undermines the right to a fair trial when crucial evidence is lost due to state carelessness.

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