California v. Trombetta (1983)
- Docket
- 83-305
- Decided
- 1983-01-01
Summary
Question: Does the Due Process Clause of the Fourteenth Amendment require law enforcement agencies to preserve breath samples of suspected drunk drivers so that results of breath analysis tests may be used at trial? Conclusion: No. Justice Thurgood Marshall delivered the opinion of the 9-0 majority. The Court held that due process rights do not extend to the point of compelling law enforcement to preserve evidence on behalf of criminal defendants. The state’s duty to preserve evidence is limited to evidence that might be expected to play a significant role in the suspect’s defense. Such evidence must possess an apparent exculpatory value before it is destroyed, and it must be of such a nature that the defendant could not obtain comparable evidence by other reasonable means. States are also prohibited of not taking breath samples did not violate the Due Process Clause because the breathalyzer tests were reliable and the exculpatory value of breath samples was very low. Additionally, defendants could have used alternate means to disprove the test results.