This summary was computer-generated without any editorial revision. It is not official, has not been checked for accuracy, and is NOT citable.
Facts
The Defendant was charged with three counts of aggravated battery with a deadly weapon after allegedly striking the victim with a rock during a domestic disturbance. Police found the victim with a head injury and the Defendant with blood on his body and clothes. Although the rock was photographed at the scene, it was not collected or preserved for testing, which the Defendant argued could have provided exculpatory evidence supporting the victim's grand jury testimony that someone else committed the assault (paras 1-3, 7).
Procedural History
- District Court, Date Unspecified: The trial court denied the Defendant's motion to dismiss the indictment but granted the motion to suppress all evidence related to the rock (paras 1, 3).
Parties' Submissions
- Plaintiff-Appellant (State): Argued that the trial court erred in applying the three-part test from State v. Chouinard to suppress evidence regarding the rock, as the police had no duty to collect it. The State also contended that the Defendant was not prejudiced by the absence of the rock (paras 4, 6, 11).
- Defendant-Appellee: Asserted that the failure to preserve the rock deprived him of due process, as it prevented him from testing the rock for exculpatory evidence, such as fingerprints or biological material, which could corroborate the victim's testimony that someone else committed the assault (paras 1, 7, 11).
Legal Issues
- Did the police have a duty to collect and preserve the rock as material evidence?
- Was the rock material to the Defendant's case?
- Did the failure to preserve the rock prejudice the Defendant?
- Did the trial court abuse its discretion in suppressing all evidence related to the rock?
Disposition
- The Court of Appeals affirmed the trial court's suppression of all evidence related to the rock (para 15).
Reasons
Per Chavez J. (Donnelly and Alarid JJ. concurring):
The Court applied the three-part test from State v. Chouinard to determine whether the failure to preserve the rock violated the Defendant's due process rights. First, the Court found that the police had a duty to collect and preserve the rock because it was central to the State's case as the alleged weapon used in the assault (paras 5-8). Second, the rock was deemed material because it was necessary to prove an essential element of the crime—use of a deadly weapon—and could have provided exculpatory evidence (paras 9-10). Third, the Defendant was prejudiced by the loss of the rock, as it prevented him from testing it to challenge the State's evidence or corroborate the victim's testimony (paras 11-12).
The Court emphasized that the trial court is in the best position to assess materiality and prejudice and has discretion to determine the appropriate remedy. The suppression of all evidence related to the rock was a reasonable remedy to ensure due process, and the trial court did not abuse its discretion in issuing this order (paras 13-15).