State of Tennessee, Appellee v. Marvin K. Ferguson, Appellant

Summary

The Tennessee Supreme Court affirmed the Court of Criminal Appeals' judgment, holding that the trial was fundamentally fair despite the State's negligent destruction of a videotape of field‑sobriety tests. The Court rejected the pure bad‑faith analysis of Arizona v. Youngblood and adopted a balancing approach that considers the State’s duty to preserve evidence, the degree of negligence, the significance of the missing evidence, and the sufficiency of the remaining record. Accordingly, no reversal or remedial sanction was warranted.