State v. Walker

Under the Fourteenth Amendment, “unless a criminal defendant can show bad faith on the part of the police, failure to preserve potentially useful evidence does not constitute a denial of due process of law.” Arizona v. Youngblood, 488 US 51, 58, (1988).

Defendant appealed a judgment of conviction for second-degree manslaughter, fourth-degree assault, and reckless driving. Defendant assigned error to the trial court’s denial of his motion to exclude evidence of his vehicle’s mechanical condition. Defendant argued that the State violated his due process rights by failing to preserve the vehicle and the state trooper acted in bad faith in not preserving the vehicle. Under the Fourteenth Amendment, “unless a criminal defendant can show bad faith on the part of the police, failure to preserve potentially useful evidence does not constitute a denial of due process of law.” Arizona v. Youngblood, 488 US 51, 58, (1988). The Court held that the trial court did not error in denying the motion because the trial court found that the state did not act in bad faith in failing to preserve the useful evidence regarding the vehicle and the State was acting in accord with its standard impound practices. Affirmed.