DAVID STARR WILLIAMS, APPELLANT,
v.
THE STATE OF FLORIDA, APPELLEE
AI-generated. These summaries, headnotes, and key points are machine-generated and may contain errors or omissions. Always verify against the full opinion text below. Not legal advice.
David Starr Williams appealed the denial of post-conviction relief seeking DNA testing of destroyed physical evidence, contending it would favor his defense. The court affirmed, holding that because the evidence was destroyed pursuant to a valid 1975 court order before DNA testing became foreseeable, Williams failed to demonstrate the bad faith required under Arizona v. Youngblood to challenge the destruction.
The court held that Williams failed to establish bad faith destruction of evidence because he did not demonstrate that police intentionally destroyed evidence they believed would exonerate him or that the evidence had apparent exculpatory value at the time of destruction. The court also held that the 80-year sentence is legal because the underlying convictions were for first-degree felonies at the time of sentencing in 1974, making life imprisonment a possible punishment.
[1] A defendant seeking relief based on the destruction of potentially exculpatory evidence must prove that the State acted in bad faith.
[2] Bad faith in the destruction of evidence exists only when police intentionally destroy evidence they believe would exonerate a defendant.
Previewing 2 of 6 headnotes on this case. FLexlaw’s editorially structured points of law — every proposition, pinpointed — are reserved for members.
Join FLexlaw to unlock all legal intelligence“in order to prevail on a claim involving loss or destruction of DNA evidence that is potentially useful to his defense, Williams would have to prove that the State acted in bad faith.”
Establishes the legal standard for challenging destruction of evidence under Youngblood
Previewing 1 of 3 key quotes on this case — the court’s exact language, pinpointed for members.
Join FLexlaw to unlock all legal intelligenceWilliams was convicted in 1974 of second-degree murder and breaking and entering with assault. Physical evidence used to convict him was destroyed pur…
The full statement of facts, procedural history, and disposition for this case are member content.
Join FLexlaw to unlock all legal intelligence© FLexlaw, Inc. — AI-generated enrichments are proprietary. All rights reserved.
Explore caselaw by topic → Browse Dna Testing cases and more on FLexlaw
FLETCHER, Judge.
David Starr Williams appeals from the trial court’s denial of post-conviction relief pursuant to rules 3.853 and 3.800, Florida Rules of Criminal Procedure. We affirm.
Williams contends that DNA testing of physical evidence held by the police would favor his defense.
However, physical evidence used to convict Williams was destroyed pursuant to a valid court order entered in 1975.
Therefore, in order to prevail on a claim involving loss or destruction of DNA evidence that is potentially useful to his defense, Williams would have to prove that the State acted in bad faith. See Arizona v. Youngblood, 488 U.S. 51, 109 S.Ct. 333, 102 L.Ed.2d 281 (1988).1 Under Youngblood, bad faith exists only when police intentionally destroy evidence they believe would exonerate a defendant. Youngblood explained that the “presence or absence of bad faith ... must necessarily turn on the police’s knowledge of the exculpatory value of the evidence at the time it was lost or destroyed.” 488 U.S. at 56 n. *, 109 S.Ct. 333 Evidence that has not been examined or tested by government agents does not have “apparent exculpatory value” and thus cannot form the basis of a claim of bad faith destruction of evidence.
Youngblood and its federal and state progeny have rejected due process claims based on the government’s failure to preserve evidence “of which no more can be said than that it could have been subjected to tests, the results of which might have exonerated the defendant”; see also King v. State, 808 So. 2d 1237, 1242 (Fla.2002) (holding that a defendant failed to show bad faith on the part of the State in destroying hair and tissue evidence, in part because the defendant failed to show the police made a “conscious effort to prevent the defense from securing the evidence”); Merck v. State, 664 So. 2d 939, 942 (Fla.1995) (holding that the defendant failed to show bad faith in a police detective’s failure to preserve a pair of pants found at a crime scene, because the detective believed they did not have evidentiary value). Recent cases have explained that in the 1970s it was not foreseeable that DNA matching would become the powerful forensic tool that it is today.
Thus, the state could not have known at the time that any of the evidence would ever be of any benefit to the defense. See King v. State, 808 So. 2d 1237, 1242 (Fla.2002). King notes that prior to 1981, Florida statutes did not require a medical examiner’s office to maintain specimens for any length of time, and only after 1981 was that office required to keep specimens for one year. Here, it has been nearly thirty years since the physical evidence was destroyed post-trial and pursuant to a valid court order, when its usefulness was at that time deemed over. Williams has not asserted a claim of bad faith or explained any prejudice in this instance. It does not appear from the record that there was any irregularity in the destruction of the physical evidence in this case.
Accordingly Williams is not entitled to relief.
Williams’ additional claim, that his eighty year sentence is illegal, has been raised and ruled upon in multiple prior post-conviction motions. Williams’ convictions for second degree murder and breaking and entering with assault were, in 1974, first degree felonies punishable by life imprisonment. See § 782.04(2), Fla. Stat. (Supp.1974); § 810.01(1), Fla. Stat. (1973).2 Williams was sentenced to thirty years for the breaking and entering with assault conviction, and to fifty years for the second degree murder conviction, to run consecutively. Williams’ eighty year sentence is therefore not illegal.
Affirmed.
. Additionally, Florida courts have held that the unavoidable consumption of testing material does not trigger a constitutional due process violation. See State v. T.L.W., 457 So. 2d 566 (Fla. 2d DCA 1984); State v. Herrera, 365 So. 2d 399 (Fla. 3d DCA 1978).
. The crime date was December 25, 1974.
Cases With Similar Vibessemantic neighbors from the corpus
Citator
Cited By
-
State v. Elkins Gomez, 915 So. 2d 698 (Fla. 3d DCA 2005)…owing of bad faith on the part of the police or prosecution. Youngblood, 488 U.S. at 58, 109 S.Ct. 333. “Under Youngblood, bad faith exists only when police intentionally destroy evidence they believe would exonerate a defendant.” Williams v. State, 891 So. 2d 621, 622 (Fla. 3d DCA 2005). Without a showing of bad faith on the part of the police or prosecution, the failure to preserve potentially useful evidence does not constitute a denial of due process. Youngblood, 488 U.S. 51, 109 S.Ct. 333; Williams, 891…1 / 2
-
Jordan v. State, 950 So. 2d 442 (Fla. 3d DCA 2007)…tate contends. If the swabs are found to be missing, the defendant may then present a claim that the swabs are missing as a result of bad faith. See Arizona v. Youngblood, 488 U.S. 51, 57-58, 109 S.Ct. 333, 102 L.Ed.2d 281 (1988); Williams v. State, 891 So. 2d 621, 622 (Fla. 3d DCA 2005). Accordingly, we reverse the order denying Jordan’s motion for DNA testing and remand for further proceedings consistent herewith. . Rule 3.853 authorizes DNA testing only where a movant states "how the DNA testing requeste…
-
Moore v. State, 903 So. 2d 238 (Fla. 2d DCA 2005)…he State’s bad faith destruction of exculpatory evidence violated his due process rights. Id. at 504 n. 7. The circuit court denied the request for DNA testing and the Youngblood claim after an eviden-tiary hearing. Id. at 504. In Williams v. State, 891 So. 2d 621 (Fla. 3d DCA 2005), the circuit court considered a Youngblood claim when ruling on a rule 3.853 motion. However, the opinion is silent as to the procedure by which the Youngblood claim was presented for the court’s consideration. We express no opin…
Previewing 3 of 8 citing cases — full citator treatment, depth of discussion, and citing context are member features.
Join FLexlaw to unlock all legal intelligenceAuthorities Cited
- Arizona v. Youngblood, 488 U.S. 51 (U.S. 1988)
- Amos Lee King v. State, 808 So. 2d 1237 (Fla. 2002)
- Merck v. State, 664 So. 2d 939 (Fla. 1995)
- State v. Herrera, 365 So. 2d 399 (Fla. 3d DCA 1978)
- State v. T.L.W., 457 So. 2d 566 (Fla. 2d DCA 1984)