State of Arkansas v. Lee Earnest Clarks, 2nd

Summary

The court held that the State’s appeal was authorized because it presented issues requiring the correct and uniform administration of criminal law. On the merits, the court clarified that a defendant bears the burden of proving either that destroyed evidence had apparent exculpatory value and was not reasonably replaceable, or that potentially useful evidence was destroyed in bad faith. Because the circuit court improperly shifted those burdens and treated an unintentional routine deletion as bad faith, the court reversed and remanded.