Lawrence William Patterson v. State of Florida
199 So. 3d 253
| Fla. | 2016Background
- Patterson was convicted of arson relating to fires that destroyed his truck and house; the truck was inspected by State and insurer investigators, photographed, sampled, then destroyed by the insurer five months before Patterson was charged.
- Patterson’s expert did not physically examine the truck but reviewed ~300 photographs and testified the fire was electrical/accidental; State experts who had examined the truck testified the fire was intentionally set based on their inspection and the same photographs and samples.
- Before trial Patterson moved to dismiss or, alternatively, to exclude testimony by State experts who physically examined the truck, arguing destruction of the truck denied him due process by preventing equal expert access.
- The trial court denied relief; the First District affirmed, distinguishing Lancaster (where no photos or samples were preserved) and applying Youngblood to require bad faith for relief when only "potentially useful" evidence is lost.
- The Florida Supreme Court granted review to resolve the district conflict and held Youngblood governs destruction of potentially useful evidence; because there was no evidence of bad faith and extensive photographs/samples existed, no due process violation occurred.
Issues
| Issue | Patterson's Argument | State's Argument | Held |
|---|---|---|---|
| Whether permitting State experts who physically examined destroyed truck to testify violated due process | Destruction prevented Patterson’s expert from examining truck, creating unfair "unlevel" expert field; trial evidence should be excluded or case dismissed | Youngblood controls: destroyed evidence was only potentially useful; relief requires showing State bad faith, which is absent | No due process violation; Youngblood standard applies; no bad faith shown, and photographs/samples allowed meaningful defense |
| Proper legal standard for destroyed evidence that is potentially useful | Apply Lancaster rule to preclude testimony or otherwise require parity between experts | Apply Youngblood/Trombetta distinction: Brady applies to material exculpatory evidence; otherwise defendant must prove bad faith | Youngblood governs; Lancaster (pre-Youngblood) disapproved where it conflicts with Youngblood |
| Whether destroyed truck constituted Brady material (material exculpatory evidence) | Implied argument that truck was critical and its destruction was equivalent to suppression of exculpatory evidence | Truck at most potentially useful; photographs/samples preserved; not undisclosed material exculpatory evidence | Truck was not Brady material; only potentially useful evidence, so bad faith required and not shown |
| Whether photographs/samples sufficed to prevent unfairness created by inability to physically inspect | Patterson argued physical inspection parity was necessary for a fair challenge to State experts | State argued preserved photos/samples allowed defense expert to meaningfully rebut State expert opinions | Photographs/samples and cross-examination permitted meaningful challenge; factual distinction from Lancaster justified admitting State experts’ testimony |
Key Cases Cited
- Arizona v. Youngblood, 488 U.S. 51 (1988) (loss of potentially useful evidence requires bad faith by the State for due process relief)
- Brady v. Maryland, 373 U.S. 83 (1963) (suppression of material exculpatory evidence violates due process)
- California v. Trombetta, 467 U.S. 479 (1984) (distinguishes potentially useful evidence from material exculpatory evidence; preservation limits)
- Patterson v. State, 153 So. 3d 307 (Fla. 1st DCA 2014) (affirming conviction; applying Youngblood and distinguishing Lancaster)
- Lancaster v. State, 457 So. 2d 506 (Fla. 4th DCA 1984) (pre-Youngblood decision excluding State experts who examined destroyed truck because no photos/samples were preserved)
- Beasley v. State, 18 So. 3d 473 (Fla. 2009) (summarizes difference between Brady and Youngblood analyses)