Arizona v. Youngblood

Summary

Chief Justice Rehnquist's majority opinion held that police failure to preserve potentially useful evidence violates due process only if the defendant shows bad faith. The failure to refrigerate clothing and test semen samples was, at worst, negligent, so Youngblood suffered no due process violation. The Court also held that police have no constitutional duty to perform particular tests and reversed and remanded. Justice Stevens concurred in the judgment, relying on the circumstances of the case and the adverse-inference instruction, but rejected a categorical bad-faith requirement. Justice Blackmun, joined by Justices Brennan and Marshall, dissented, arguing that loss of materially exculpatory evidence can render a trial unfair regardless of police intent and that Youngblood's conviction should remain overturned.