Arizona v. Youngblood

Arizona v. Youngblood, 488 U.S. 51 (1988), is a United States Supreme Court case concerning the limits of Constitutional due process in criminal law.

Arizona v. Youngblood
Argued October 11, 1988
Decided November 29, 1988
Full case nameArizona, Petitioner v. Larry Youngblood
Citations488 U.S. 51 (more)
109 S. Ct. 333; 102 L. Ed. 2d 281; 1988 U.S. LEXIS 5404; 57 U.S.L.W. 4013
Case history
PriorCert. to the Arizona Court of Appeals
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
Chief Justice
William Rehnquist
Associate Justices
William J. Brennan Jr. · Byron White
Thurgood Marshall · Harry Blackmun
John P. Stevens · Sandra Day O'Connor
Antonin Scalia · Anthony Kennedy
Case opinions
MajorityRehnquist, joined by White, O'Connor, Scalia, Kennedy
ConcurrenceStevens
DissentBlackmun, joined by Brennan, Marshall
Laws applied
U.S. Const. amend. XIV

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 U.S. 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, it 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

On remand to the Arizona Court of Appeals, the court again reversed on state law grounds.[2]

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.[3]

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.[4]

See also

References
  1. Arizona v. Youngblood, 488 US 51, 58 (1988).
  2. State v. Youngblood, 790 P.2d 759, 760 (Ariz. App. 2d Div. 1989), vacated, 844 P.2d 1152 (Ariz. 1993)
  3. "Innocence Project Larry Youngblood web page accessed November 3, 2008". Innocenceproject.org. Archived from the original on September 4, 2013. Retrieved December 19, 2012.
  4. "Innocence Project Larry Youngblood web page accessed October 4, 2012". Innocenceproject.org. Archived from the original on September 4, 2013. Retrieved December 19, 2012.
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