State v. Blackwell

In State v. Blackwell, 245 Ga. App. 135, 137-141 (2) (b), (c) (537 SE2d 457) (2000) however, the exculpatory value of the destroyed evidence was apparent where the evidence consisted of a urine sample which had been subjected to two tests for illegal drugs, one of which was negative. The state also acted in bad faith, because the urine sample was destroyed by the state crime lab without notice to the defendant, after the defendant had sought an independent analysis of the sample, after the trial court had entered an order permitting such analysis, after the crime lab was notified that the defendant wanted the sample, and after the state represented to the defendant that the sample was unavailable. Id. at 141-142 (2) (d).