Supreme Court of Florida

Lawrence William Patterson, Petitioner v. State of Florida, Respondent

August 25, 201641 Fla. L. Weekly Supp. 350

Summary

The court held that destruction of potentially useful evidence violates due process only when the defendant proves bad faith, regardless of whether the requested remedy is dismissal or exclusion of testimony. Because the truck was destroyed without evidence of bad faith and extensive photographs allowed Patterson to challenge the State experts’ conclusions, the court found no due process violation, approved the result below, and disapproved the contrary preexisting approach. No separate opinions were filed.