Arizona v. Youngblood

This Source Verification Page documents Arizona v. Youngblood, 488 U.S. 51 (1988), a decision of the Supreme Court of the United States cited in Claim I of the Supplemental Motion. The Court held that when evidence is merely potentially useful rather than apparently exculpatory, the failure to preserve that evidence violates due process only if the defendant demonstrates that law enforcement acted in bad faith. The decision establishes the constitutional standard governing claims involving lost or destroyed evidence.

Related SMAR Citation

"[Arizona v. Youngblood (1988)]"

Case Name

Arizona v. Youngblood

Citation

488 U.S. 51 (1988)

Date

November 29, 1988

Verification Source

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

Source Location

Supreme Court of the United States

Highlighted Pages

1, 6

Referenced in the Supplemental Motion

Page 46, Paragraph 94

Source Status

✔ Original Supreme Court opinion obtained and reviewed.

✔ Relevant passages highlighted.

✔ Publicly available source.

✔ Included within the Source Verification Archive.

Cited to Support

Lyle C. May alleges that law enforcement agencies involved in the investigation of his case failed to properly preserve, maintain, account for, or disclose physical evidence and that publicly documented evidence-management failures by the Asheville Police Department (APD) and the Buncombe County Sheriff's Office (BCSD) warrant further judicial inquiry. Claim I cites Arizona v. Youngblood, 488 U.S. 51 (1988), for the constitutional principle that when lost, destroyed, or unavailable evidence is merely potentially useful rather than apparently exculpatory, a defendant must demonstrate bad faith by law enforcement to establish a due process violation.

The decision establishes that the failure to preserve potentially useful evidence, standing alone, does not violate the Due Process Clause absent evidence of bad faith. May relies upon this authority in support of his allegations that the handling of physical evidence in his Buncombe County, North Carolina prosecution raises constitutional questions requiring further judicial review under the standards established in Youngblood.

Supporting Documents

Original Opinion

Official published opinion of the Supreme Court of the United States.

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Highlighted Research Copy

Working research copy containing the highlighted portions relied upon in the Supplemental Motion.

View PDF →