Arizona v. Youngblood

488 U.S. 51 (1988)

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Nature of the Case

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Facts

A young boy was brutally sexually assaulted and threatened. His mother took him to the local hospital and evidence was collected. The police collected the kit but did not freeze or refrigerate the clothes. Nine days after the attack, the boy picked out his assailant from a photo lineup. The next day a police criminologist, examined the sexual assault kit and determined that sexual contact had occurred. He performed no other tests, although he placed the assault kit back in the refrigerator. He did not test the clothing at this time. Youngblood (D) was arrested four weeks later. The evidence collected could not finger D as the culprit in the crime, and this was clearly brought out in the trial. D's principal defense at trial was that the boy had erred in identifying him as the perpetrator of the crime. In this connection, both a criminologist for the State and an expert witness for respondent testified as to what might have been shown by tests performed on the samples shortly after they were gathered, or by later tests performed on the samples from the boy's clothing had the clothing been properly refrigerated. The court instructed the jury that, if they found the State had destroyed or lost evidence, they might 'infer that the true fact is against the State's interest.' D was still convicted based on the testimony of the boy alone. D claimed that the police mishandling of the evidence violated his rights of due process; if the evidence would have been handled properly, it might have exonerated him. D appealed. The Court of Appeals reversed.