Arizona v. Youngblood was an important Supreme Court case. Along with California v. Trombetta, it helped set rules for what a court should do if evidence that would have helped the defendant has been destroyed. In some cases, it means the charges against the defendant are dropped.
Anyone accused of DUI in California is guaranteed a right to “due process” by the United States Constitution. This means you deserve a fair, unbiased trial—and it means you have a right to know about, and use, the evidence that the prosecutor has gathered. Sometimes, however, evidence gets destroyed, either intentionally, by accident, or because it wasn’t stored properly. If the destroyed evidence would have helped your DUI defense, or if it was destroyed intentionally, the law holds that you have been deprived of a fair trial, and you have a right to have the case against you dismissed.
This right comes largely from a ruling in a famous Supreme Court case, Arizona v. Youngblood.
What was the Arizona v. Youngblood case all about?
Arizona v. Youngblood started with an innocent man who was accused of a crime purely because he had a bad eye.
In 1983, a 10-year old boy was at a church carnival when he was kidnapped by a middle aged man. The man not only abducted him, but sexually assaulted him multiple times before letting him go. When the boy was found, he said that the man who attacked him had a disfigured right eye.
Police soon arrested Larry Youngblood, who had a bad left eye, and the boy picked him out of a lineup. Meanwhile, however, police had also secured semen samples with a rape kit, as well as the boy’s clothing which had semen on it. Since Youngblood was innocent, his lawyer asked that the semen samples be tested. Unfortunately, the samples from the rape kit had not been prepared with enough semen for DNA testing, and the clothing had not been refrigerated, spoiling the sample. The result was that this conclusive DNA evidence was not available for Youngblood’s defense. Youngblood was convicted anyway.
Youngblood fought his case. At first, his appeal got his conviction overturned because of the lost evidence. However, the prosecution then took the case to the Supreme Court. In 1988, it issued a ruling. The Supreme Court’s decision did not help Youngblood—it upheld the original conviction—but it did establish important rules for addressing missing or destroyed evidence.
Eventually, years later, Youngblood’s lawyer won a motion to have the DNA evidence re-tested with newer, better technology. In 2000, Larry Youngblood was found innocent and had his name cleared. The semen sample was linked to a different man, a convicted sex offender, who went on to serve time for the child’s assault.
How does the Youngblood decision affect my DUI case?
Arizona v. Youngblood was not a victory for Youngblood himself. The court sent him to prison even though it later turned out he was innocent. This tragic case, however, established clear rules that help other criminal defendants.
Thanks to Arizona v. Youngblood and another case, California v. Trombetta, if evidence is destroyed or lost by the government, you may be able to get your case dismissed—but it depends on the circumstances. Your charges could be dismissed if either of the following is true:
- The destroyed or mishandled evidence would clearly have helped your case (for example, a DUI blood test sample with a low blood alcohol content). Or,
- The evidence may or may not have helped your case, but there was an act of “bad faith” by law enforcement or the prosecutor—such as intentionally destroying it.
Only one of these two conditions has to be met for you to file a request known as a Trombetta-Youngblood motion. If the judge agrees with the motion, he or she will dismiss one or more of the charges against you. It could mean no DUI charge at all, or it could mean that a more serious charge such as DUI Causing Injury is no longer viable, and only lesser charges can be brought against you. In some cases it means you walk completely free.
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