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Keywords

defendantappealtrialmotiondue processgood faithrespondent

appealdue processgood faithrespondent

Related Cases

California v. Trombetta, 467 U.S. 479, 104 S.Ct. 2528, 81 L.Ed.2d 413

Facts

In unrelated incidents in 1980 and 1981, several respondents were stopped on suspicion of drunken driving in California and submitted to intoxilyzer tests, which indicated blood-alcohol concentrations above the legal limit. The arresting officers did not preserve the breath samples, which the respondents claimed would have been useful to challenge the test results. The Municipal Court denied their motions to suppress the intoxilyzer results, leading to appeals that were consolidated and ultimately ruled in favor of the respondents by the California Court of Appeal.

Although it was technically feasible to preserve samples of respondents' breath, the arresting officers, as was their ordinary practice, did not do so.

Issue

Does the Due Process Clause of the Fourteenth Amendment require law enforcement agencies to preserve breath samples from intoxilyzer tests in order for the results to be admissible in criminal prosecutions?

The question presented is whether the Due Process Clause requires law enforcement agencies to preserve breath samples of suspected drunken drivers in order for the results of breath-analysis tests to be admissible in criminal prosecutions.

Rule

The Due Process Clause does not impose a constitutional duty on law enforcement to preserve evidence unless it possesses exculpatory value that was apparent before it was destroyed and is of such a nature that the defendant would be unable to obtain comparable evidence by other reasonably available means.

The constitutional duty of the States to preserve evidence is limited to evidence that might be expected to play a role in the suspect's defense.

Analysis

The Supreme Court analyzed the case by determining that the breath samples were collected solely for the purpose of providing data to the intoxilyzer, and the results of the tests, not the breath itself, were what was presented at trial. The Court concluded that the failure to preserve the samples did not constitute a violation of the respondents' rights, as the officers acted in good faith and according to their normal practices. Furthermore, the Court found that the respondents had alternative means to challenge the accuracy of the intoxilyzer results without the preserved samples.

In failing to preserve breath samples for respondents, the officers here were acting 'in good faith and in accord with their normal practice.'

Conclusion

The Supreme Court reversed the decision of the California Court of Appeal, holding that the failure to preserve breath samples did not violate the Due Process Clause, and remanded the case for further proceedings.

Accordingly, the judgment of the California Court of Appeal is reversed, and the case is remanded for further proceedings not inconsistent with this opinion.

Who won?

The State prevailed in the case, as the Supreme Court ruled that the failure to preserve breath samples did not constitute a constitutional violation, allowing the intoxilyzer results to be admissible in court.

The State's failure to preserve breath samples for respondents did not constitute a violation of the Federal Constitution.

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