Arizona v. Youngblood
Citation and Court
488 U.S. 51 (1988), Supreme Court of the United States
Facts
Larry Youngblood was convicted of child molestation, sexual assault, and kidnapping. The police failed to properly refrigerate semen samples taken from the victim’s clothing, rendering them useless for exculpatory DNA testing. Youngblood argued the failure to preserve the evidence violated his due process rights.
Issue
Whether the failure by police to preserve potentially exculpatory evidence constitutes a violation of due process under the Fourteenth Amendment.
Holding
The failure to preserve potentially useful evidence does not constitute a denial of due process unless the defendant can show bad faith on the part of the police.
Rule / Doctrine
The Due Process Clause requires the government to preserve evidence only when that evidence possesses exculpatory value that was apparent before its destruction and the defendant cannot obtain comparable evidence by other reasonably available means. Where evidence is merely “potentially useful” rather than materially exculpatory, the government’s failure to preserve it violates due process only if the defendant demonstrates bad faith.
Significance
Youngblood draws a critical line between materially exculpatory evidence (per Brady v. Maryland, suppression always violates due process) and potentially useful evidence (bad faith required). This limits Brady’s reach and places a heavy burden on defendants to prove police acted in bad faith when evidence is lost or destroyed rather than withheld.