STATE OF FLORIDA, APPELLANT,
v.
REGINALD ANTONIO HAMPTON, APPELLEE
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The State appeals the trial court's dismissal of charges against Reginald Hampton based on alleged discovery violations. The appellate court reverses, holding that the State did not violate due process by failing to preserve a retail store surveillance videotape that was never in the government's possession and was not exculpatory evidence.
The State did not violate due process rights. To establish a due process violation for failure to preserve evidence, the defendant must show either that the destroyed evidence was material and exculpatory, or that the State acted in bad faith. Here, Appellee failed to establish the evidence was exculpatory and did not meet the burden of showing bad faith by the State.
[1] A due process violation occurs when the State fails to preserve potentially useful evidence only if the defendant demonstrates that the evidence was destroyed in bad fait…
[2] A defendant must show that destroyed evidence was material and exculpatory, or that potentially useful evidence was destroyed in bad faith, to establish a due process vio…
Previewing 2 of 4 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“Under this analysis, it was incumbent on Appellee to show that the destroyed evidence was material, exculpatory evidence or that potentially useful evidence was destroyed (or not preserved) by the State acting in bad faith.”
Establishes the legal standard for due process violation claims under Arizona v. Youngblood—defendant must prove materiality/exculpatory nature or bad faith.
Previewing 1 of 3 key quotes on this case — the court’s exact language, pinpointed for members.
Join FLexlaw to unlock all legal intelligenceAppellee was arrested at a retail store where a surveillance videotape existed. The sheriff's office requested a copy of the videotape at the time of …
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The State challenges the dismissal of the information against Appellee. It contends the trial court erred in finding that it had committed a discovery violation by failing to retrieve and preserve a surveillance videotape from the retail store where Appel-lee had been arrested prior to the store erasing the tape. It argues that the tape was never in the government’s possession, was not exculpatory, and there was no evidence of bad faith. We agree and reverse.
Appellee filed a “Motion for Sanctions and in the Alternative Motion to Dismiss,” alleging that the State had violated Brady v. Maryland, 373 U.S. 83, 83 S.Ct. 1194, 10 L.Ed.2d 215 (1963), and failed to comply with Florida Rule of Criminal Procedure *1108.220(b)(1) by failing to provide a surveillance videotape within its possession and control. The State filed a response alleging that the sheriffs office had requested a copy of the videotape at the time of Appel-lee’s arrest and the store was to make it available. However, on more than one occasion, the arresting deputy returned to the store to get the videotape, but he was told that there was no tape and any tape would have been erased within 24 hours. The State contended that any failure in preserving the videotape was that of the store. After a brief hearing, during which no evidence was presented, the court rendered an order granting the motion to dismiss and releasing Appellee.
Below, Appellee framed the issue in terms of whether the State had committed a Brady violation, which is the basis on which the trial court granted the discharge. We agree with the State that the real issue in this case is whether the State violated Appellee’s due process rights by failing to preserve evidence, pursuant to Arizona v. Youngblood, 488 U.S. 51, 109 S.Ct. 333, 102 L.Ed.2d 281 (1988). Under this analysis, it was incumbent on Appellee to show that the destroyed evidence was material, exculpatory evidence or that potentially useful evidence was destroyed (or not preserved) by the State acting in bad faith. Here, Appellee did not establish that the evidence was exculpatory, only that it might be useful to impeach the testimony of the deputy. Under these circumstances, it was Appellee’s burden to show that the State acted in bad faith, a burden that was not met.
REVERSED AND REMANDED.
GRIFFIN, TORPY and JACOBUS, JJ., concur.
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Yero v. State, 138 So. 3d 1179 (Fla. 3d DCA 2014)…ore than one occasion; and the deputy testified that the video depicted Yero in possession of an item that matched the physical description of Ashurst’s wallet (thus, the deputy viewed the evidence as having inculpatory value). In State v. Hampton, 113 So. 3d 109, 110 (Fla. 5th DCA 2013), the Fifth District held that similar conduct did not constitute bad faith. There, the State failed to retrieve and preserve a surveillance video from the retail store where the defendant had been arrested. Id. at 109. “[T]h…
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State v. Jaron Miller, 159 So. 3d 992 (Fla. 5th DCA 2015)…- ■ ent state. . We have jurisdiction pursuant to Florida Rule of Appellate Procedure 9.140(c)(1)(B). . We reject Appellee’s invitation to analyze this case as one where the State has failed to meet its discovery obligations. See State v. Hampton, 113 So. 3d 109 (Fla. 5th DCA 2013). . The trial court's conclusion that gross negligence equates to bad faith is contrary to existing caselaw. Additionally, the evidence, at most, established negligence, not gross negligence, on the part of the Orange County Sher…
Authorities Cited
- Brady v. Maryland, 373 U.S. 83 (U.S. 1963)
- Arizona v. Youngblood, 488 U.S. 51 (U.S. 1988)