Why is the case important?
An individual convicted of child molestation challenged his conviction based on the state’s failure to preserve certain evidence.
Facts of the case
“On October 29, 1983, 10-year-old David was abducted from a church carnival. The abductor molested and sodomized the boy, then returned him to the carnival an hour and a half later. David’s mother took him to the Kino Hospital, where a doctor examined him and used a sexual assault kit to collect evidence. The police collected the kit and the boy’s clothes. The evidence from the kit was refrigerated, but the clothing was not. Nine days after the attack, David positively identified Larry Youngblood as the abductor from a photo lineup. The next day, a police criminologist examined the sexual assault kit and determined that sexual contact had occurred, but he did not test the clothing at that time. Youngblood was indicted on charges of sexual assault, kidnapping, and child molestation. The state moved to compel him to provide samples to compare with those from the sexual assault kit, but the trial court denied the motion because there was not enough sample material in the kit to make a valid comparison. In January 1985, the police criminologist tested the boy’s clothing for the first time and received inconclusive data.At trial, police witnesses testified as to what the tests might have shown had they been conducted closer to the time the evidence was gathered. The court instructed the jury to consider the facts “against the state’s interests” if they found the state had lost or destroyed evidence by conducting the tests later. The jury found the defendant guilty. The Arizona Court of Appeals reversed and held that, when identity is an issue at trial, the loss or destruction of evidence that could remove the defendant from suspicion is a denial of due process. The Supreme Court of Arizona denied the petition for review.”
Does the United States Constitution (the Constitution) require the state to preserve evidentiary material that may be useful to a criminal defendant?
“No. The majority first observed that this case required them to address what might loosely be called the area of constitutionally guaranteed access to evidence. Pursuant to Brady v. Maryland the court observed that in the past it held the suppression by the prosecution of evidence favorable to the accused upon request violates due process where the evidence is material either to guilt or to punishment, irrespective of the good faith or bad faith of the prosecution. Further, based on United States v. Agurs the court observed that it has been held the prosecution had a duty to disclose some evidence of this description even though no requests were made for it, but at the same time we rejected the notion that a ‘prosecutor has a constitutional duty routinely to deliver his entire file to defense counsel.’
Based on the facts of this case, the majority held that the police did not violate Brady or Agurs. The State disclosed relevant police reports to respondent, which contained information about the existence of the swab and the clothing, and the boy’s examination at the hospital. The State provided respondent’s expert with the laboratory reports and notes prepared by the police criminologist, and respondent’s expert had access to the swab and to the clothing.
Unless a criminal defendant can show bad faith on the part of the police, failure to preserve potentially useful evidence does not constitute a denial of due process of law. In this case, the police collected the rectal swab and clothing on the night of the crime
The Court held that unless Youngblood could show bad faith on the part of the police, the failure to preserve potentially useful evidence did not constitute a denial of due process. The Court found that the delays in testing followed standard procedure and that tests were performed as soon as defendant was arrested. Witnesses from both sides testified as to what might have been shown by timely performed tests or by later tests performed on samples from the victim’s clothing had they been properly refrigerated. The Court found that although there was a likelihood that the preserved materials would have enabled Youngblood to exonerate himself, that the State did not attempt to use any of these materials in its case-in-chief. The Court further held that the failure to refrigerate the clothing and to perform tests was at worst negligence, that none of the information was concealed from Youngblood, and that the evidence was available to him. The Court reversed the judgment of the Arizona Court of Appeals.
- Case Brief: 1988
- Petitioner: Arizona
- Respondent: Larry Youngblood
- Decided by: Rehnquist Court
Citation: 488 US 51 (1988)
Argued: Oct 11, 1988
Decided: Nov 29, 1988