Arizona v. Youngblood
A plain-English summary from Criminal Defense Resources™, a free resource for pro per/pro se defendants and their families.
- Court
- U.S. Supreme Court
- Decided
- Citation
- 488 U.S. 51 (1988)
What did the court decide?
The U.S. Supreme Court held that when police fail to preserve evidence that is only potentially useful to the defense, there is no violation of federal due process unless the defendant can show the police acted in bad faith. In this case, police did not refrigerate clothing or test samples in time, which the Court described as at worst negligent, so the Arizona Court of Appeals' reversal of the conviction was itself reversed.
Why does it matter?
It sets the federal constitutional rule for lost or destroyed evidence, which is harder to meet than the Brady rule for evidence the prosecution hides. Some states give more protection under their own law; in Arizona, for example, a defendant may still ask the trial court for a Willits instruction (see State v. Willits and State v. Glissendorf) even without proof of bad faith.
Where can I read the full opinion?
Read the full opinion on Cornell Law School LII →
Always read the full opinion and check whether later cases have limited or changed it. A summary can leave out important details.