Saturday, November 2, 2013

Arizona v. Youngblood case brief

Arizona v. Youngblood case brief summary
488 U.S. 51 (1988)

Defendant was convicted of child molestation, sexual assault, and kidnapping. The Arizona Court of Appeals reversed the judgment, holding that the State's failure to preserve semen samples from the victim's body and clothing was material to the defense and a denial of due process. Certiorari was granted to consider the extent that the Due Process Clause of the Fourteenth Amendment required the State to preserve evidentiary material.

Defendant claimed that the victim erred in identifying him and that if proper and timely tests had been performed on the evidence, defendant would have been exonerated. The Court reversed the judgment of the state court of appeals.


  • The Court held that unless defendant could show bad faith on the part of the police, the failure to preserve potentially useful evidence did not constitute a denial of due process. 
  • The Court found that the delays in testing followed standard procedure and that tests were performed as soon as defendant was arrested. 
  • Witnesses from both sides testified as to what might have been shown by timely performed tests or by later tests performed on samples from the victim's clothing had they been properly refrigerated. 
  • The Court found that although there was a likelihood that the preserved materials would have enabled defendant to exonerate himself, that the State did not attempt to use any of these materials in its case-in-chief. 
  • The Court further held that the failure to refrigerate the clothing and to perform tests was at worst negligence, that none of the information was concealed from defendant, and that the evidence was available to defendant.


The judgment was reversed and the case was remanded for further proceedings.

Recommended Supplements for Criminal Procedure Criminal Procedure: Examples & Explanations, Sixth Edition
Emanuel Law Outline: Criminal Procedure

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