November 29, 2013
Something that the vast majority of us should be thankful for, but is probably not anything that would normally cross our minds, is that we never had to spend almost a decade in prison for a crime that we didn’t commit.
Larry Youngblood, if he were still alive today, could not consider himself as fortunate as the rest of us; he was convicted for the 1983 kidnapping, molestation, and sexual assault of a ten-year-old boy. He was exonerated in 2000.
The Supreme Court actually heard Youngblood’s case in 1988, and it’s ruling – handed down 25 years ago today – was responsible for putting him back in prison after his conviction was overturned by the Arizona Court of Appeals two years earlier.
The issue on which the Arizona Court of Appeals based its overturning of Youngblood’s conviction, and the one under consideration in the Supreme Court case, was whether the failure to preserve potentially exculpatory evidence by law enforcement constitutes a due process violation under the Constitution.
Here are the facts of the case:
In 1983, a ten-year-old boy was abducted from a carnival “by a middle-aged man of medium height and weight.” I won’t go into the gruesome details here, but the boy was raped multiple times by the man, and then returned to the carnival about an hour and a half later.
The boy returned to his mother and informed her of what happened. They stopped at a hospital on the way home, where the boy was treated for his injuries. The physician also used a “sexual assault kit” to collect DNA evidence of the attack. The police collected the kit and placed it in refrigeration at the police station. At the hospital, the police also collected the boy’s underwear and T-shirt, which was not refrigerated or frozen.
Nine days after the attack, the police asked the boy to identify his assailant from a photographic lineup, and he proceeded to identify Youngblood. Youngblood was charged with the crime and the jury convicted him. The conviction was based largely on eye witness identification since the police improperly stored the evidence and it had degraded – making accurate DNA testing impossible at the time. Expert witnesses at trial stated that, had the evidence been stored correctly, test results might have conclusively exonerated Youngblood of the charges.
Youngblood appealed his conviction, arguing that the improper storage of the DNA evidence, which could have exonerated him, was a violation of his constitutional due process rights. The Arizona Court of Appeals agreed, reversing his conviction.
The Supreme Court agreed to review the case, and oral arguments were heard on October 11, 1988. In an unusually fast turnaround time for a Supreme Court decision, the Court ruled on the case on November 29, 1988.
In the 6 to 3 decision, the Court reversed the Arizona appeals court, reinstating Youngblood’s conviction – finding that, absent a showing of bad faith on the part of the police, “failure to preserve potentially useful evidence does not constitute a denial of due process of law.”
After the case finished making its rounds through the Arizona state court system, Youngblood was sent back to prison in 1993.
As I mentioned earlier, Youngblood was exonerated in 2000 by test results using new, more sophisticated DNA-testing technology (the request for the test was made by his attorney). Youngblood himself, however, didn’t have long to enjoy his new freedom: he died in 2007.
Nonetheless, Youngblood’s death shielded him from learning of the Supreme Court’s 2011 Connick v. Thompson ruling, in which the Supreme Court overturned a jury verdict that awarded $14 million to a man who spent 14 years on death row for crimes he did not commit. The conviction was the result of (some would argue gross) mishandling of evidence by the prosecutor’s office.
The ruling itself wouldn’t have been as upsetting to Youngblood as the fact that Justice Scalia’s concurring opinion cites Youngblood as precedent to support the Thompson holding.
Thus, although Youngblood’s case is often used as an example of how the criminal justice system can fail in extreme ways, the Youngblood Supreme Court case continues to be used to the detriment of wrong-convicted individuals like Youngblood himself.
So it’s probably good that Youngblood isn’t around to see his case’s legacy.