Arizona v. Youngblood, 488 U.S. 51 (1988)

In Youngblood, a divided Supreme Court held that the Fourteenth Amendment due process clause does not require the government to preserve evidence that could conclusively prove the defendant innocent.

Weeks after a young boy was abducted and raped, Youngblood was arrested and charged with the crime after the boy picked his photo from a lineup. Youngblood maintained his innocence and requested that a semen stain on the boy’s clothing be tested to determine the rapist’s blood type. Unfortunately, such testing could not be performed because the police had neglected to refrigerate the stained clothing. Youngblood was convicted at trial, but an appellate court reversed the conviction because the destroyed evidence deprived Youngblood of an opportunity to prove his innocence.

The U.S. Supreme Court reinstated Youngblood’s conviction by a vote of six to three. Relying on California v. Trombetta, the majority ruled that the government’s failure to preserve potentially exculpatory evidence violates due process only if the government intentionally destroys the evidence in bad faith. Since the police did not intentionally allow the evidence to deteriorate in Youngblood’s case, the Court reasoned that he was not entitled to any relief even though the police’s negligence deprived him of an opportunity to establish his innocence conclusively. Youngblood thus sharply limits the responsibility of the government to preserve potentially exculpatory evidence for testing.

In 2000, twelve years after the Court sent Youngblood back to prison, he was exonerated when more advanced DNA testing on the stained clothing established that he was not the rapist.

DAVID A. MORAN

References and Further Reading

Imwinkelried, Edwin, and Norman Garland. Exculpatory Evidence, 2nd ed. Charlottesville, VA: Michie Publications, 1996.
Stacy, Tom, The Search for Truth in Constitutional Criminal Procedure, Columbia Law Review 91 (1991): 1369.
Whitaker, Barbara. ‘‘DNAFrees Inmate Years After Justices Rejected Plea.’’ The New York Times, August 11, 2000.

Cases and Statutes Cited