State of Arizona v. Pablo Isaac Hernandez

Summary

The court held that a defendant is entitled to a Willits instruction only when the state fails to preserve evidence that was obviously material and reasonably accessible at the time of the investigation, that could have tended to exonerate the defendant, and that omission causes prejudice. Because officers already had identified Hernandez and had no reason to anticipate an alternate-driver defense, uncollected fingerprint and DNA evidence was not obviously material and would not necessarily have exonerated him. The court vacated the court of appeals' decision and affirmed Hernandez's conviction and sentence.