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Cal. v. Trombetta

Supreme Court of the United States

April 18, 1984, Argued ; June 11, 1984, Decided

No. 83-305

Case Summary

Procedural Posture

Finding that due process required the State to preserve captured evidence or its equivalent for the use of respondents, the Court of Appeal of California, First Appellate District, granted two defendants new trials and ordered that Intoxilyzer results could not be admitted as evidence against the other two defendants. The State unsuccessfully petitioned the Supreme Court of California for certiorari, but the court granted certiorari.

Overview

Defendants submitted to Intoxilyzer tests upon being stopped for drunken driving. After registering blood-alcohol concentrations substantially higher than 0.10 percent, defendants were charged with driving while intoxicated in violation of Cal. Veh. Code § 23102 (1981). Defendants moved to suppress the test results on the ground that the arresting officers failed to preserve the samples of defendants' breath. Such motions were denied. Upon consolidation, the state appellate court concluded that due process required law enforcement agencies to establish rigorous procedures to preserve the captured evidence or its equivalent for the use of defendants. After the state supreme court denied certiorari, the State sought further review. The court reversed and remanded, holding that the due process clause of the U.S. Const. amend. XIV did not require the State to preserve breath samples in order to introduce the results of breath-analysis tests at trial. Even if it was assumed that the Intoxilyzer results were inaccurate and that the breath samples might, therefore, have been exculpatory, it did not follow that defendants were without alternative means of demonstrating their innocence.

Outcome

The Court reversed the state court's judgment and remanded the case for further proceedings consistent with the Court's opinion.

LexisNexis® Headnotes

 

 

Constitutional Law > ... > Fundamental Rights > Procedural Due Process > Scope of Protection

Criminal Law & Procedure > ... > Discovery & Inspection > Brady Materials > General Overview

Constitutional Law > ... > Fundamental Rights > Procedural Due Process > General Overview

HN1  Procedural Due Process, Scope of Protection

The due process clause of U.S. Const. amend. XIV requires the state to disclose to criminal defendants favorable evidence that is material either to guilt or to punishment.

 

Civil Procedure > ... > Jurisdiction on Certiorari > Considerations Governing Review > State Court Decisions

Criminal Law & Procedure > Appeals > Appellate Jurisdiction > Certified Questions

Criminal Law & Procedure > Preliminary Proceedings > Pretrial Motions & Procedures > Suppression of Evidence

HN2  Considerations Governing Review, State Court Decisions

A judgment affirming a suppression order is reviewable in the United States Supreme Court under 28 U.S.C.S. § 1257(3).

 

Criminal Law & Procedure > ... > Discovery & Inspection > Brady Materials > General Overview

Evidence > Relevance > Preservation of Relevant Evidence > Exclusion & Preservation by Prosecutors

Constitutional Law > ... > Fundamental Rights > Procedural Due Process > General Overview

Constitutional Law > ... > Fundamental Rights > Procedural Due Process > Scope of Protection

Criminal Law & Procedure > Defenses > General Overview

Criminal Law & Procedure > Defenses > Right to Present

HN3  Discovery & Inspection, Brady Materials

Under the due process clause of U.S. Const. amend. XIV, criminal prosecutions must comport with prevailing notions of fundamental fairness. This standard of fairness is interpreted to require that criminal defendants be afforded a meaningful opportunity to present a complete defense. To safeguard that right, the Supreme Court has developed what might loosely be called the area of constitutionally guaranteed access to evidence. Taken together, this group of constitutional privileges delivers exculpatory evidence into the hands of the accused, thereby protecting the innocent from erroneous conviction and ensuring the integrity of the criminal justice system.

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467 U.S. 479 ; 104 S. Ct. 2528 ; 81 L. Ed. 2d 413 ; 1984 U.S. LEXIS 103 ; 52 U.S.L.W. 4744

CALIFORNIA v. TROMBETTA ET AL.

Prior History:  [1]  CERTIORARI TO THE COURT OF APPEAL OF CALIFORNIA, FIRST APPELLATE DISTRICT.

Disposition:  142 Cal. App. 3d 138, 190 Cal. Rptr. 319, reversed and remanded.