Jason Bernard Matthews v. State
11-17-00098-CR
| Tex. | Jul 14, 2017Background
- On Feb. 23, 2016 police executed a no‑knock search at a hotel room registered to co‑defendant Brittany Lawson; officers found ~18.11 grams of a crystal substance that DPS tested as methamphetamine, drug paraphernalia, and other drugs. Appellant Jason Matthews was detained nearby and items bearing his paperwork were found in the room and vehicle.
- DPS analyst Ashley Zelinski tested the substance and confirmed methamphetamine and weight prior to destruction.
- Appellant requested independent testing; the trial court ordered delivery to Armstrong Forensic Laboratory for re‑testing on Dec. 14, 2016.
- The Abilene Police Department inadvertently destroyed the physical evidence (and related photos/videos) on Oct. 21, 2016 after receiving disposition paperwork for the co‑defendant that lacked a notation that a co‑defendant’s case remained pending.
- Appellant moved to suppress the chemist’s testimony and sought relief based on alleged Due Process violations under the U.S. Constitution and the Texas Constitution’s Due Course of Law clause. The trial court denied suppression; a jury convicted Matthews of possession with intent to deliver and assessed 8 years’ imprisonment.
Issues
| Issue | Plaintiff's Argument | Defendant's Argument | Held |
|---|---|---|---|
| Whether destruction of potentially useful evidence violated Due Process / Due Course of Law | Matthews: negligent destruction of evidence prejudiced his ability to retest and merits relief; Texas Due Course provides greater protection and may require remedy despite absence of bad faith | State: evidence was only "potentially useful," not obviously exculpatory; destruction was inadvertent/administrative error (no bad faith); Texas clause affords no greater protection here | Court affirmed: evidence was only potentially useful and destroyed inadvertently (no bad faith); no U.S. Due Process violation and Texas Due Course offers no greater protection in these circumstances |
Key Cases Cited
- Arizona v. Youngblood, 488 U.S. 51 (distinguishing material exculpatory evidence from merely potentially useful evidence; bad‑faith requirement for the latter)
- Illinois v. Fisher, 540 U.S. 544 (applying Youngblood principles to destruction of evidence)
- Ex parte Napper, 322 S.W.3d 202 (Tex. Crim. App. 2010) (discussing material vs. potentially useful evidence and bad‑faith standard under Texas law)
- Guzman v. State, 955 S.W.2d 85 (Tex. Crim. App. 1997) (standard of review for suppression rulings)
- Carmouche v. State, 10 S.W.3d 323 (Tex. Crim. App. 2000) (bifurcated review of historical facts and legal conclusions)
- Univ. of Tex. Med. Sch. at Houston v. Than, 901 S.W.2d 926 (Tex. 1995) (noting Texas "due course" and federal "due process" are not meaningfully different)