Arizona v. Youngblood

Facts

On October 29, 1983, David, a 10-year-old boy, was abducted from a carnival and taken to an unidentified house. For 1.5 hours, the kidnapper molested and sodomized the boy repeatedly. The kidnapper then drove him back to the carnival. The boy was taken to the hospital where he was treated for rectal injuries. The doctor also used a “sexual assault kit” to collect evidence of the attack. The doctor collected samples from the boy’s rectum and mouth. The doctor also obtained samples of the boy’s saliva, blood, and hair. The police placed the kit in a secure refrigerator at the police station. They did not run any tests on it. The police also collected the boy’s underwear and T-shirt. This clothing was not refrigerated or frozen. The boy identified the defendant in a photographic lineup, and the defendant was located and arrested four weeks later on December 9, 1983.

In January 1985, the police criminologist examined the boy’s clothing for the first time. He found one semen stain on the boy’s underwear and another on the rear of his T-shirt. The criminologist tried to obtain blood group substances from both stains, but was unsuccessful.

The defendant’s principal defense at trial was that the boy had erred in identifying him as the perpetrator of the crime. Experts testified as to what might have been shown by tests had they been performed on the samples shortly after they were gathered, or by later tests performed on the samples from the boy’s clothing had the clothing been properly refrigerated. The jury still found the defendant guilty.

The Arizona Court of Appeals reversed the judgment of conviction because the State had failed to preserve semen samples from the victim’s body and clothing. It stated that “‘such loss is material to the defense and is a denial of due process.” The State appealed.