Supreme Court of the United States

Illinois v. Fisher

February 23, 2004540 U.S. 544

Summary

The Court held per curiam that destruction of potentially useful evidence does not violate due process absent police bad faith, even when a discovery request is pending or the evidence is central to the defense. Because the destroyed substance had repeatedly tested positive for cocaine and the police destroyed it in good faith under normal procedures, Fisher established no federal due process violation. The Court also held that it had jurisdiction because the state appellate court relied solely on federal due process, notwithstanding an available state-law ground. It reversed and remanded. Justice Stevens concurred in the judgment without any other Justice joining him. He maintained that destruction of evidence could make a trial fundamentally unfair without bad faith, agreed that this case did not present that circumstance, and believed certiorari should have been denied.

Holding

  • Whether a pending discovery request eliminates the bad-faith requirement for destruction of potentially useful evidence.. A pending discovery request does not eliminate the requirement that a defendant establish police bad faith when the destroyed evidence was only potentially useful.
  • Whether the importance of potentially useful evidence creates an exception to the bad-faith requirement.. The bad-faith requirement applies even when potentially useful evidence is asserted to be the defendant's only hope for exoneration or determinative of the case.
  • Whether the possibility of an independent state-law ground deprived the Court of jurisdiction.. The Court had jurisdiction because the state appellate court based its judgment solely on federal due process.

Docket 03-374

Cited authorities

  • Rule 415(g)(i)

Cited by

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