AI Generated Opinion Summaries

This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.

Facts

Police responded to a domestic violence call and found the Defendant's girlfriend injured with a head wound. A bloodied rock was discovered at the scene but was only photographed and not collected as evidence. The Defendant was arrested at the scene, and the girlfriend later testified that someone else attacked her with the rock, though she could not identify the assailant (paras 2-3).

Procedural History

• Trial Court, June 19, 1991: The trial court suppressed evidence related to the rock, finding that the State's failure to preserve it violated the Defendant's due process rights (paras 6-7).
• Court of Appeals, June 29, 1993: The Court of Appeals affirmed the trial court's suppression order, applying a three-part test from prior case law to find that the State had a duty to collect and preserve the rock (para 7).

Parties' Submissions

• State: Argued that the police were not obligated to collect every piece of evidence at the crime scene and that the three-part test from prior case law did not apply because the rock was never collected. Instead, the State contended that federal standards from Trombetta and Youngblood should apply, requiring bad faith for suppression (paras 5, 9-12).
• Defendant: Claimed that the State breached its duty to preserve material evidence by failing to collect the rock, which prejudiced the defense by preventing testing and impeachment of witnesses. The Defendant relied on the three-part test from Lovato and Chouinard to argue for suppression (paras 4, 8).

Legal Issues

• Did the State's failure to collect the rock from the crime scene violate the Defendant's due process rights?
• Was the suppression of evidence related to the rock appropriate under the circumstances?

Disposition

• The Supreme Court of New Mexico reversed the Court of Appeals' decision and the trial court's suppression order, remanding the case for trial (paras 27-28).

Reasons

Per Baca J. (Ransom and Franchini JJ. concurring):

• The Court distinguished between the failure to preserve evidence already collected and the failure to gather evidence in the first place. The three-part test from Lovato and Chouinard applies only to cases where evidence was collected and later lost or destroyed, not to cases of failure to gather evidence (paras 11, 17-18).
• The Court rejected the application of federal standards from Trombetta and Youngblood because those cases also involved evidence that had been collected and later destroyed, which was not the situation here (paras 12-13).
• A two-part test was adopted for cases involving failure to gather evidence: (1) the evidence must be material to the defense, and (2) the conduct of the investigating officers must be evaluated for bad faith or gross negligence. If the failure was merely negligent or in good faith, sanctions are inappropriate, but the Defendant may argue the investigation's shortcomings at trial (paras 24-26).
• The rock was deemed material to the defense, but the failure to collect it was found to be a judgment call or ordinary negligence, not bad faith or gross negligence. Therefore, suppression of evidence related to the rock was inappropriate (paras 27-28).