Arizona v. Youngblood

Arizona v. Youngblood

Argued October 11, 1988
Decided November 29, 1988
Full case name Arizona, Petitioner v. Larry Youngblood
Citations

488 U.S. 51 (more)

109 S. Ct. 333; 102 L. Ed. 2d 281; 1988 U.S. LEXIS 5404; 57 U.S.L.W. 4013
Prior history Cert. to the Court of Appeals of Arizona
Holding
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.
Court membership
Case opinions
Majority Rehnquist, joined by White, O'Connor, Scalia, Kennedy
Concurrence Stevens
Dissent Blackmun, joined by Brennan, Marshall

Arizona v. Youngblood, 488 U.S. 51 (1988), was an important United States Supreme Court case about the limits of Constitutional due process under criminal law.

Background

A boy was molested and sodomized. The rape kit was preserved in a refrigerator, but the boy's clothes (containing samples of the assailant's semen) were not preserved in a refrigeration unit. At a later date, criminalists were unable to do testing on the clothing because it had deteriorated as a result of not being refrigerated. The boy picked the defendant out of a photo lineup as his assailant.

Next, the case developed as follows:

At trial, expert witnesses testified that respondent might have been completely exonerated by timely performance of tests on properly preserved semen samples. Respondent was convicted of child molestation, sexual assault, and kidnaping in an Arizona state court. The Arizona Court of Appeals reversed the conviction on the ground that the State had breached a constitutional duty to preserve the semen samples from the victim's body and clothing.
—Arizona v. Youngblood, 488 US 51, 51 (1988).

The defendant claimed that the state disposed of potentially exculpatory evidence by not properly preserving the evidence.

Opinion of the Court

The Supreme Court held that there was no constitutional violation in this case. In the Court's holding, the Court stated: “[w]e therefore hold that 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.”[1] The court relied on United States v. Marion, 404 U.S. 307 (1971), United States v. Lovasco, 431 U.S. 783 (1977), and other cases for its reasoning.

Subsequent developments

In 2000, on request from Youngblood's attorneys, the police department tested the degraded evidence using new, sophisticated DNA technology. Those results exonerated Youngblood, and he was released from prison in August 2000, and charges were dismissed.[2]

Shortly thereafter, the DNA profile from the evidence was entered into the national convicted offender databases. In early 2001, officials got a hit, matching the profile of Walter Cruise, who was then serving time in Texas on unrelated charges. In August 2002, Cruise was convicted of the crime and sentenced to twenty-four years in prison.[3]

See also

References

  1. ↑ Arizona v. Youngblood, 488 US 51, 58 (1988).
  2. ↑ "Innocence Project Larry Youngblood web page accessed November 3, 2008". Innocenceproject.org. Retrieved December 19, 2012.
  3. ↑ "Innocence Project Larry Youngblood web page accessed October 4, 2012". Innocenceproject.org. Retrieved December 19, 2012.

External links