Arizona v. Youngblood explained

Litigants:Arizona v. Youngblood
Arguedate:October 11
Argueyear:1988
Decidedate:November 29
Decideyear:1988
Fullname:Arizona, Petitioner v. Larry Youngblood
Usvol:488
Uspage:51
Parallelcitations:109 S. Ct. 333; 102 L. Ed. 2d 281; 1988 U.S. LEXIS 5404; 57 U.S.L.W. 4013
Prior:Cert. 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.
Majority:Rehnquist
Joinmajority:White, O'Connor, Scalia, Kennedy
Concurrence:Stevens
Dissent:Blackmun
Joindissent:Brennan, Marshall
Lawsapplied:U.S. Const. amend. XIV

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.

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:

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,, United States v. Lovasco,, 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

Notes and 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. Web site: Innocence Project Larry Youngblood web page accessed November 3, 2008 . Innocenceproject.org . December 19, 2012 . http://webarchive.loc.gov/all/20130904233031/http%3A//www.innocenceproject.org/Content/Larry_Youngblood.php . September 4, 2013 . dead .
  4. Web site: Innocence Project Larry Youngblood web page accessed October 4, 2012 . Innocenceproject.org . December 19, 2012 . http://webarchive.loc.gov/all/20130904233031/http%3A//www.innocenceproject.org/Content/Larry_Youngblood.php . September 4, 2013 . dead .