Today marks the 29th anniversary of the landmark Supreme Court case of Arizona v. Youngblood in which the Supreme Court held that a defendant must show that police destroyed evidence in bad faith to claim a due process violation. This case is particularly troubling because the defendant was later exonerated of the crime for which he was convicted. This is not the first or last time the Supreme Court has affirmed the conviction of someone who was ultimately proved innocent.
The case behind Arizona v. Youngblood is disturbing to say the least. On October 29th, 1983, ten-year-old David L. was abducted from a church carnival near Interstate 10 in Pima County Arizona. That night, David’s mother received a call from the pastor’s wife reporting that David had returned to the church. David had been abducted, raped, and returned to the church. David’s mother took him to a hospital, were a rape kit was preformed and samples were taken.
David reported that a black man with a bad eye had asked him to help unload a tent from his car. David agreed, and was taken out to the desert and raped twice before being dropped off at the church. A composite sketch was drawn up and police began to look for the suspect. Police had a suspect in mind, Larry Youngblood had been convicted of robbery ten years prior, and matched the description. Police made a photo lineup of six men, including Mr. Youngblood, each with an eye blotted out. Detectives took the photos to David at school and he identified Mr. Youngblood. Mr. Youngblood was arrested ten days after and charged with child molestation, sexual assault, and kidnapping. Police officers failed to refrigerate the samples taken from David thus corrupting the samples for future testing.
At Mr. Youngblood’s arraignment, David was escorted by two police officers to the proceedings. When David saw Mr. Youngblood David asked the officer, “is that him?”. Unfortunately, this warning sign would go unheeded, along with other inconsistencies. David said that he had been abducted by a man with a two-door car, Mr. Youngblood only owned a four-door car. David had also said the man who had attacked him had grey hair, but Mr. Youngblood had black hair, and experts proved his hair had never been dyed. David described the man that attacked him as having a limp, due to one leg being shorter than the other, but Mr. Youngblood had no such abnormality. David also said that the man who attacked him listened to county music, by Mr. Youngblood hated country music.
However, at trial Mr. Youngblood’s defense did not go well. Mishandled witnesses did more damage to Mr. Youngblood’s case, and the only alibi he had was his girlfriend who testified he was sleeping on her couch at the time of the attack. The only expert witness called by the defense established that if the sample collected by police had been refrigerated Mr. Youngblood would most likely be excluded as a suspect. The jury took forty minutes to find Mr. Youngblood guilty and sentence him to twenty-four years in prison. Mr. Youngblood appealed his conviction arguing he had been denied due process by the State falling to maintain the samples for testing.
Mr. Youngblood’s conviction was reversed by the Arizona Court of Appeals. However, two years later that same court unanimously reinstated Mr. Youngblood’s conviction holding that the state was under no obligation to not destroy evidence so long as it wasn’t done in bad faith, or for otherwise malicious and unlawful reasons. Mr. Youngblood then sought a writ of certiorari from the Supreme Court and was granted cert in 1988.
The Supreme Court heard arguments on October 11th, 1988. Mr. Youngblood argued that his due process rights had been violated by police failing to preserve evidence that could have excluded him. Mr. Youngblood also argued that no showing of “bad faith” was needed to make out a due process claim regarding the destruction of evidence.
The State argued that Mr. Youngblood had been convicted based upon his own testimony and the witness descriptions. The State emphasized that they had not intentionally destroyed the evidence, and that the testing Mr. Youngblood proposed to do could have also shown he was the suspect. Thus, the State reasoned he had not been denied due process.
The Supreme Court rendered its judgment on November 29th, 1988. In a 6 – 3 decision the majority led by Chief Justice William Rehnquist held that Mr. Youngblood’s 5th amendment due process rights had not been violated. The Court reasoned that to make out a due process claim regarding the destruction of evidence, Mr. Youngblood would have top show police intentionally destroyed the evidence to prevent him from testing it, other wise his rights had not been violated. Thus, the Court affirmed Mr. Youngblood’s conviction.
Justice Stevens wrote his own concurrence with the majority emphasized that the jury could have chosen to ignore the evidence, and at best it would have been inconclusive, rather than dispositive to his case.
Justice Harry A. Blackman wrote the dissent, joined by Justice Brennan and Justice Marshall. Justice Blackman argued that regardless of the states intention, the destruction of evidence had denied Mr. Youngblood a fair trial. He further argued that the distinction between good and bad faith was improper, and encouraged police to violate defendant’s rights.
Aftermath and Conclusion
With his conviction reaffirmed, Mr. Youngblood returned to jail. Mr. Youngblood appealed again arguing that his Arizona state constitutional right to due process had been violated by the destruction of evidence. The Arizona Court of Appeals agreed, and again Mr. Youngblood’s conviction was again dismissed. Arizona appealed the ruling to the Arizona Supreme Court. The Arizona Supreme Court held that the Arizona constitutional right to due process operated under the same guidelines as the federal right, thus reinstating his conviction in 1993. Mr. Youngblood was then set to serve the remaining 10 ½ years of his sentence. In 1998, Mr. Youngblood was released on parole but returned to prison the following year for failing to register his address in the sex offender registry.
In 2000, Mr. Youngblood’s lawyers from “The Innocence Project” sought to test the samples again using new methods. The results exonerated Mr. Youngblood and he was formally released and his charges dismissed. However, because of a waiver Mr. Youngblood had to sign to be allowed to test the samples Mr. Youngblood never received any compensation for his confinement. In 2001 the results were entered into a nation database. The database returned a match for Walter Calvin Cruise, a black male with a bad eye and limp with two prior convictions for child sexual assault in Texas and one in Arizona who was currently serving a time in Texas for possession of cocaine.
In 2002 Mr. Cruise was charged, tried, and convicted for the sexual assault of David and sentenced to twenty-four years in prison. Mr. Cruise apologized to the court saying he was unaware another man was serving a sentence for his crime. Mr. Youngblood would die in 2007, penniless, but exonerated after nine years in prison. David would developed sever emotional issues as a result of the trauma he underwent. David was convicted multiple times of assault against various girlfriends. David would late be disowned by his parents for stealing money to fuel his cocaine and alcohol addiction. On June 16th, 2004, David Leon was killed by a train in Tucson Arizona just feet away from Interstate 10. His autopsy revealed a staggeringly high blood alcohol concentration.
The Supreme Court never acknowledged its mistake. Arizona v. Youngblood has been cited in three major decisions by the Supreme Court sense it was decided and its holding remains good law today. Unfortunately, the same decision that would have condemned Mr. Youngblood, is still used today to justify convictions were the state has destroyed vital evidence. With Experienced Legal Representation, you can protect yourself against wrongful convictions.
Written by Hunter J. White
 Arizona v. Youngblood, 488 U.S. 51, 109 S. Ct. 333 (1988)
 Pseudonym used in court documents.