California v. Trombetta

In California v. Trombetta, 467 U.S. 479 (1984), the United States Supreme Court held that the defendant had failed to show bad faith where the police "did not destroy the samples in a calculated effort to circumvent the . . . requirement that the prosecution disclose evidence that is material to a defendant's guilt. . . . The officers here were acting 'in good faith and in accord with their normal practice.' The record contains no allegation of official animus towards the defendants or of a conscious effort to suppress exculpatory evidence." ( Trombetta, supra, 467 U.S. at p. 488.) The Supreme Court held that the preservation obligation is "limited to evidence that might be expected to play a significant role in the suspect's defense." (Trombetta, supra, 467 U.S. at p. 488.) To meet the standard of constitutional materiality, the evidence at issue "must both possess an exculpatory value that was apparent before the evidence was destroyed" and it must "be of such a nature that the defendant would be unable to obtain comparable evidence by other reasonably available means." (Id. at p. 489.) The court found no violation of due process in the failure to preserve breath samples in a driving under the influence case. "The Due Process Clause of the Fourteenth Amendment does not require that law enforcement agencies preserve breath samples in order to introduce the results of breath-analysis tests at trial." (Id. at p. 491.) "Whatever duty the Constitution imposes on the States to preserve evidence, that duty must be limited to evidence that might be expected to play a significant role in the suspect's defense. To meet this standard of constitutional materiality ..., evidence must both possess an exculpatory value that was apparent before the evidence was destroyed, and be of such a nature that the defendant would be unable to obtain comparable evidence by other reasonably available means." (Id. at pp. 488-489, ) The Court held: "Whatever duty the Constitution imposes on the States to preserve evidence, that duty must be limited to evidence that might be expected to play a significant role in the suspect's defense. To meet this standard of constitutional materiality , evidence must both possess an exculpatory value that was apparent before the evidence was destroyed, and be of such a nature that the defendant would be unable to obtain comparable evidence by other reasonably available means." ( Id. at pp. 488-489, ) The United States Supreme Court held that "whatever duty the Constitution imposes on the States to preserve evidence, that duty must be limited to evidence that might be expected to play a significant role in the suspect's defense. To meet this standard of constitutional materiality , evidence must both possess an exculpatory value that was apparent before the evidence was destroyed, and be of such a nature that the defendant would be unable to obtain comparable evidence by other reasonably available means." (Id. at pp. 488-489, ) Yhe high court limited the state's affirmative duty to preserve evidence to that which 'might be expected to play a significant role in the suspect's defense.' (Trombetta, supra, 467 U.S. at p. 488.) This standard of 'constitutional materiality' imposes two requirements that a defendant must meet in order to show a due process violation. As an initial matter, the evidence must 'possess an exculpatory value that was apparent before it was destroyed.' (Id. at p. 489.) Additionally, it must 'be of such a nature that the defendant would be unable to obtain comparable evidence by other reasonably available means.' (Ibid.) The Court concluded that the Due Process Clause did not require law enforcement agencies to preserve the breath samples of suspected drunken drivers for the results of breath-analysis tests to be admissible in criminal prosecutions. First, the officers in that case did not destroy the breath samples in a conscious effort to suppress exculpatory evidence, but acted " 'in good faith and in accord with their normal practice.'" Id. at 488. Second, the court held that "whatever duty the Constitution imposes on the States to preserve evidence, that duty must be limited to evidence that might be expected to play a significant role in the suspect's defense." Id. at 488. "Under the Due Process Clause of the Fourteenth Amendment, criminal prosecutions must comport with prevailing notions of fundamental fairness. The Court has long interpreted this standard of fairness to require that criminal defendants be afforded a meaningful opportunity to present a complete defense." Trombetta, supra, 467 U.S. at 485. In Trombetta, the chances were extremely low that preserved breath samples would have been exculpatory, and the defendant had other means of attacking the accuracy of the testing device, so the court found no due process violation in the State's failure to preserve the breath samples. Id. at 490-491. In California v. Trombetta, the defendants, who were prosecuted for drunk driving, challenged the destruction of their breath samples after tests performed by the State using an Intoxilyzer machine showed that the samples contained alcohol. The defendants claimed that "had a breath sample been preserved, they would have been able to impeach the incriminating Intoxilyzer results." Id. at 483. The Court found no due process violation, however, because the possibility that an independent test of the breath samples would have exculpated the defendants was "extremely low" and because there was evidence that the defendants could have impeached the Intoxilyzer results by other means. Id. at 489-490.