Arizona v. Youngblood (1988)
- Docket
- 86-1904
- Decided
- 1988-01-01
Summary
Question: Does the state’s failure to preserve potentially useful evidence constitute a denial of due process? Conclusion: No. Chief Justice William H. Rehnquist delivered the opinion for the 6-3 majority. The Supreme Court held that a criminal defendant must show bad faith on the part of the police to prove that the loss or destruction of evidence was a denial of due process. Requiring the police to retain every potentially useful piece of evidence places an undue burden on the police, while the bad faith restriction limits the police’s duty to what serves the interests of justice. The Court also held that, in this case, the police’s failure to refrigerate the clothing could at worst be negligent, but not in bad faith. In his opinion concurring in judgment, Justice John Paul Stevens wrote that, even without the Court’s ruling, the state has a strong interest in properly preserving as much evidence as possible. He also argued that there was no way to definitively say what the evidence might have shown and the jury still ruled in favor of the prosecution, which suggests that the evidence would not have been sufficient to exonerate Youngblood. Justice Stevens also argued that, while he concurred in the judgment, he found the majority’s opinion much broader than necessary to decide this case. Justice Harry A. Blackmun wrote a dissenting opinion in which he argued that, regardless of the state’s intent, police action that results in the defendant’s failure to receive a fair trial represents a denial of due process. He also argued that there is no bright-line distinction between good faith and bad faith police action, and therefore that guideline does not adequately protect the rights of criminal defendants. Without any way to know what the evidence would have shown, there is no proof that it would not have been enough to exonerate Youngblood, so the police’s failure to preserve the evidence effectively deprived Youngblood of his rights to due process. Justice William J. Brennan, Jr. and Justice Thurgood Marshall joined the dissent. "